Louie N. Elias v. W.H. Connett
Opinion
Opinion
Alarcon, J.
Louie N. Elias appeals pro se from the denial of his motion for preliminary injunction and from the dismissal of his first amended complaint for failure to state a claim upon which relief may be granted. Elias contends that the Internal Revenue Service (IRS) improperly assessed and collected taxes against him for the tax years 1974 through 1979, 1981, and 1982. He also contends that the United States waived its sovereign immunity to suit pursuant to 28 U.S.C. § 2410 . We have jurisdiction pursuant to 28 U.S.C. §§ 1291 and 1292(a)(1). We affirm.
I
On December 19, 1984, the IRS sent Elias a statutory notice of deficiency for unpaid taxes, penalties, and interest for the tax years 1974 through 1979. On September 9, 1985, the IRS sent Elias notices on IRS Form 6641, setting forth his assessed tax deficiencies for the years 1974 through 1978. Elias failed to pay the assessments for any of the tax years in question. The IRS thus levied on Elias’s funds held by Warner Brothers, Inc., Paramount Pictures Corp., Twentieth Century Fox, Universal Studios, Inc., A.S. Payroll Co., Inc., the Screen Actors Guild, and the Valley State Bank.