He cannot circumvent ANY US District Court to go to the court of appeals, they would have no jurisdiction.
If his bank accounts were seized by the FEDS, he will not be allowed to reopen an account, banks are regulated by the FEDS.
His assets were seized ”pending” investigation, if the assets were seized, the Government had probable cause that the assets were obtained illegally, there would be charges filed; there are none.
It was not tax evasion because the IRS would not derive him of his 5th Amendment right to due process before seizing his assets. That is in the ”Due Process” clause of the 5th Amendment. They generally afford you payment plans and years (like 5+) to settle the debt, he said he ”didn’t file on time” 😑
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