Pollen v. Commissioner
United States Tax Court
The Commissioner, on Apr. 13, 1972, made a jeopardy assessment against petitioners; on May 12, 1972, the United States District Court appointed a receiver who qualified on May 25, 1972; on June 9, 1972, the Commissioner mailed a statutory notice of deficiency to petitioners covering the taxable years covered by the jeopardy assessment; and on July 25, 1972, petitioners filed their petition herein for a redetermination of the taxes and additions to tax covered by the…
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The Commissioner, on Apr. 13, 1972, made a jeopardy assessment against petitioners; on May 12, 1972, the United States District Court appointed a receiver who qualified on May 25, 1972; on June 9, 1972, the Commissioner mailed a statutory notice of deficiency to petitioners covering the taxable years covered by the jeopardy assessment; and on July 25, 1972, petitioners filed their petition herein for a redetermination of the taxes and additions to tax covered by the statutory notice of deficiency. Held, respondent's motion to dismiss for lack of jurisdiction is granted. Leon I. Ross, 38 T.C.…
1Opinion of the Court
Goffe, Judge:
Respondent, on October 9,1974, filed a motion to dismiss this case for lack of jurisdiction. At the hearing on the motion, we directed the parties to file briefs, and briefs were filed on behalf of petitioner Bobbie Pollen and respondent.
FINDINGS OF FACT
The facts are not disputed. On April 13, 1972, the Commissioner made jeopardy assessments against petitioners covering the taxable years 1965 to 1967, inclusive. On May 2, 1972, after notice and demand for payment had been made, the United States of America commenced an action against petitioners in the United States District…
2Cases cited3 opinions
- Fotochrome, Inc. v. CommissionerUnited States Tax Court · 1972
- Ross v. CommissionerUnited States Tax Court · 1962
- Conlee Constr. Co. v. CommissionerUnited States Tax Court · 1970
3Cited by2 opinions
- Levine v. CommissionerUnited States Tax Court · 1987
- Pollen v. CommissionerUnited States Tax Court · 1975