Eiges v. Commissioner
United States Tax Court
R issued, on the same day, a statutory notice determining deficiencies in and additions to P-parents' 1983 and 1988 Federal income taxes, and a statutory notice of transferee liability determining P-parents' 4-year-old son's transferee liability for his parents' income tax deficiencies to the extent of the value of assets allegedly transferred to him. Jeopardy assessments were made for both determinations.
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R issued, on the same day, a statutory notice determining deficiencies in and additions to P-parents' 1983 and 1988 Federal income taxes, and a statutory notice of transferee liability determining P-parents' 4-year-old son's transferee liability for his parents' income tax deficiencies to the extent of the value of assets allegedly transferred to him. Jeopardy assessments were made for both determinations. P-parents timely filed a petition challenging respondent's determinations. R moved to dismiss for lack of jurisdiction with respect to the minor son. Held: R's motion will be denied. As…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge Francis J. Cantrel pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Cantrel, Special Trial Judge:
This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction as to Jordan Deal Eiges as transferee of the assets of Corey Don Eiges and Theresa Deal Eiges (petitioner parents), and to amend the caption to read “Corey Don Eiges and Theresa Deal Eiges, Petitioners”.
By…
2Cases cited28 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Commissioner v. SternSupreme Court of the United States · 1958
- Shiosaki v. CommissionerUnited States Tax Court · 1974
- Odend'hal v. CommissionerUnited States Tax Court · 1980
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
23 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Caban v. 600 E. 21st Street Co.District Court, E.D. New York · 2001
- Bobbs v. Comm'rUnited States Tax Court · 2005
- Estate of Galloway v. CommissionerUnited States Tax Court · 1994
- Eiges v. CommissionerUnited States Tax Court · 1993
- Estate of Galloway v. CommissionerUnited States Tax Court · 1994
1 more not listed; retrieve them via the Exa API.