Legal Opinion

United States v. Filson

Court of Appeals for the Fifth Circuit

Decided October 16, 2009No. 08-51141UnpublishedCited by 7 opinions

1Opinion of the Court

PER CURIAM: *

Roger Filson, pro se, appeals the district court’s order granting summary judgment to the United States that allowed foreclosure of a tax lien against his property. Filson argues that there is a genuine issue of material fact as to the existence of tax liabilities giving rise to the lien. For the following reasons, we AFFIRM.

I. FACTUAL AND PROCEDURAL BACKGROUND

Despite earning a combined income greater than $60,000 per year, Roger and Polly Filson filed returns with the Internal Revenue Service (“IRS”) stating that they earned zero taxable income from 1994-98. To support this…

2Cases cited15 opinions

  1. United States v. OlanoSupreme Court of the United States · 1993
  2. Paul W. Douglass v. United Services Automobile AssociationCourt of Appeals for the Fifth Circuit · 1996
  3. Landis v. North American Co.Supreme Court of the United States · 1936
  4. Johnson v. United StatesSupreme Court of the United States · 1997
  5. Montana v. United StatesSupreme Court of the United States · 1979

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3Cited by7 opinions

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  3. Minafee v. Bernalillo County Board of CommissionersDistrict Court, D. New Mexico · 2022
  4. Rawan Hayaf, LLP, Ali M. Saleh, Hayaf Saleh and Sena Edha v. Herb Frierson, in his Official Capacity as the Commissioner of Revenue of the Mississippi Department of RevenueCourt of Appeals of Mississippi · 2021
  5. Riverbend Environmental Services, LLC v. Crum & Forster Specialty Insurance CompanyDistrict Court, S.D. Mississippi · 2023

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