Legal Opinion

Harwood v. Commissioner

United States Tax Court

Decided November 7, 1984No. Docket Nos. 6557-81, 6558-81, 6559-81, 6560-81, 6561-81Published

After an opinion in these cases was filed, 82 T.C. 239 (1984), R submitted computations of deficiencies under Rule 155, Tax Court Rules of Practice and Procedure, together with proposed decisions.

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After an opinion in these cases was filed, 82 T.C. 239 (1984), R submitted computations of deficiencies under Rule 155, Tax Court Rules of Practice and Procedure, together with proposed decisions. Ps did not dispute the amounts computed by R. Rather, they filed a notice of objection and request for hearing, wherein they argued that the Court should determine the acceptability of first deeds of trust on property they owned or controlled in lieu of an appeal bond pursuant to sec. 7485(a)(2), I.R.C. 1954 as amended. Held: Argument under Rule 155 proceedings is strictly limited to consideration…

1Opinion of the Court

Virginia Z. Harwood, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Harwood v. Commissioner

Docket Nos. 6557-81, 6558-81, 6559-81, 6560-81, 6561-81

United States Tax Court

83 T.C. 692; 1984 U.S. Tax Ct. LEXIS 16; 83 T.C. No. 38;

November 7, 1984. November 7, 1984, Filed

Decisions will be entered in accordance with respondent's computations.

After an opinion in these cases was filed, 82 T.C. 239 (1984), R submitted computations of deficiencies under Rule 155, Tax Court Rules of Practice and Procedure, together with proposed decisions. Ps did not dispute the amounts computed by…

2Cases cited11 opinions

  1. Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
  2. Anthony v. CommissionerUnited States Tax Court · 1976
  3. Harwood v. CommissionerUnited States Tax Court · 1984
  4. Florence M. Barnes, and Barnes Theatre Ticket Service, Inc., an Illinois Corporation v. The Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
  5. Cloes v. CommissionerUnited States Tax Court · 1982

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