James P. Jacques, Gloria Jacques v. Internal Revenue Service
Opinion
Opinion
972 F.2d 1339 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. James P. JACQUES, Gloria Jacques, Plaintiffs-Appellants, v. INTERNAL REVENUE SERVICE, et al., Defendants-Appellees. No. 91-15992. United States Court of Appeals, Ninth Circuit. Submitted July 29, 1992. * Decided Aug. 5, 1992. Before TANG, BEEZER and KOZINSKI, Circuit Judges. 1 MEMORANDUM ** 2 James and Gloria Jacques appeal pro se the district court's dismissal of their claim pursuant to Fed.R.Civ.P. 12(b)(1) and (6). In their complaint, the Jacques allege that the Internal Revenue Service ("IRS") attempted to levy their property without first sending them a notice of deficiency and assessments pursuant to 26 U.S.C. §§ 6212 , 6214. The Jacques seek damages and injunctive relief against the IRS and a number of its employees. The district court dismissed the complaint, finding that the suit was barred by sovereign immunity, the Anti-Injunction Act, and qualified immunity. We have jurisdiction pursuant to…