Legal Opinion

Human Engineering Institute v. Commissioner

United States Tax Court

Decided October 18, 1973No. Docket Nos. 528-68, 529-68PublishedCited by 69 opinions

Petitioners' motions for the release of assets from the lien of jeopardy assessments in order to pay legal and accounting fees, to have the jeopardy assessments and deficiency notices declared null and void, and for other relief are denied.

1Opinion of the Court

OPINION

Tannenwald, Judge:

The problem presented in this proceeding is rooted in jeopardy assessments, for which notice and demand was made on September 7, 1967, against the individual petitioners in the amount of $3,405,909.01 and the corporate petitioner in the amount of $1,271,053.24. In accordance with the provisions of section 6861 (b) ,1 respondent on November 3, 1967, issued notices of deficiency for the taxable years 1953 to 1962, inclusive, consisting of deficiencies in income tax of $1,780,852.38 and additions to tax for fraud of $890,426.21 in respect of the individual petitioners…

2Cases cited26 opinions

  1. Board of Regents of State Colleges v. RothSupreme Court of the United States · 1972
  2. Goldberg v. KellySupreme Court of the United States · 1970
  3. Fuentes v. ShevinSupreme Court of the United States · 1972
  4. Boddie v. ConnecticutSupreme Court of the United States · 1971
  5. Sniadach v. Family Finance Corp. of Bay ViewSupreme Court of the United States · 1969

21 more not listed; retrieve them via the Exa API.

3Cited by69 opinions

  1. Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
  2. Petzoldt v. CommissionerUnited States Tax Court · 1989
  3. Jackson v. CommissionerUnited States Tax Court · 1979
  4. Riland v. CommissionerUnited States Tax Court · 1982
  5. Powers v. CommissionerUnited States Tax Court · 1993

64 more not listed; retrieve them via the Exa API.

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