Court of Appeals for the Fifth Circuit February 24, 2012, No. 11-60044 (A.I.M. Controls, L.L.C. v. Commissioner)

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.