Legal Opinion

Jimmie L. Stites and Doris I. Stites v. Internal Revenue Service

Court of Appeals for the Fifth Circuit

Decided June 26, 1986No. 86-2197PublishedCited by 8 opinions

1Opinion of the Court

POLITZ, Circuit Judge:

This case presents another in what at times appears to be an unending stream of frivolous tax-protestation cases. Jimmie L. and Doris I. Stites (“taxpayers”) petitioned the district court for an order quashing summonses issued by the Internal Revenue Service (IRS). The trial court dismissed the complaint and imposed sanctions under Fed.R.Civ.P. 11, awarding costs and attorney’s fees. Taxpayers do not challenge the dismissal of their complaint but appeal only the Rule 11 sanctions. We affirm.

Background

In connection with its investigation of the tax liability of taxpayers,…

2Cases cited11 opinions

  1. United States v. PowellSupreme Court of the United States · 1964
  2. Donaldson v. United StatesSupreme Court of the United States · 1971
  3. Couch v. United StatesSupreme Court of the United States · 1973
  4. James Elliott and Joseph Defley v. Leander H. Perez, Jr., Etc., Eugene E. Leon, Jr., Etc., and Frank KleinCourt of Appeals for the Fifth Circuit · 1985
  5. Hale v. HarneyCourt of Appeals for the Fifth Circuit · 1986

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3Cited by8 opinions

  1. Edward M. Farguson v. Mbank Houston, N.A.Court of Appeals for the Fifth Circuit · 1986
  2. Daniel Ross Umphlet v. Harry Connick, District AttorneyCourt of Appeals for the Fifth Circuit · 1987
  3. United States v. AlexanderDistrict Court, S.D. Texas · 1991
  4. Fischer v. Samuel Montagu, Inc.District Court, S.D. New York · 1989
  5. Cornelius Brown v. Nationwide Mutual Insurance Company, Cross-Appellant v. Nancy J. Beck, Movant-Appellant, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1986

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