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A.I.M. CONTROLS, L.L.C. v. C.I.R.

No. 11-60044.

672 F.3d 390 (2012)

A.I.M. CONTROLS, L.L.C.; RESAM Holdings Trust; Clifford William, trustee, a partner other than the tax matters partner, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

February 24, 2012.

Attorney(s) appearing for the Case

Thomas Edward Ross (argued), Ross & Associates, Houston, TX, for Petitioners-Appellants.

Teresa T. Milton (argued), Jonathan S. Cohen , John DiCicco , U.S. Dept. of Justice, Tax Div., App. Section, Clarissa C. Potter , William J. Wilkins , IRS, Gilbert Steven Rothenberg , Deputy Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for Respondent-Appellee.

Before BARKSDALE, GARZA and ELROD, Circuit Judges.

EMILIO M. GARZA, Circuit Judge:

A.I.M. Controls, L.L.C., RESAM Holdings Trust, and Clifford William (together, the Petitioners) appeal the Tax Court's order dismissing their action against the Commissioner of Internal Revenue ("Government") for lack of jurisdiction. We AFFIRM.

I

Royce and Susan Mitchell formed A.I.M. Controls, L.L.C. ("A.I.M. Controls") in 1998 as a limited liability partnership under Texas law. A.I.M. Controls comprised two partners...

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