Galusha v. Commissioner
United States Tax Court
R made a jeopardy assessment against P. At or about the same time R seized P's boat, advertised it for sale, and provided P the opportunity to post bond to avoid the sale of P's boat.
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R made a jeopardy assessment against P. At or about the same time R seized P's boat, advertised it for sale, and provided P the opportunity to post bond to avoid the sale of P's boat. Subsequently, R mailed a notice of deficiency to P, who immediately petitioned this Court and also moved for a stay of the sale under sec. 6863(b)(3), I.R.C. 1986. R asserted that sale of the boat was necessary because it is "perishable" within the meaning of sec. 6336, I.R.C. 1986. R also asserted that the boat would become "greatly reduced in price or value" within the meaning of sec. 6863(b)(3)(B)(iii),…
1Opinion of the Court
Gerald A. Galusha, Petitioner v. Commissioner of Internal Revenue, Respondent
Galusha v. Commissioner
Docket No. 17256-90
United States Tax Court
95 T.C. 218; 1990 U.S. Tax Ct. LEXIS 83; 95 T.C. No. 17;
September 4, 1990, Filed
An appropriate order will be entered staying the sale of the vessel "Anna".
R made a jeopardy assessment against P. At or about the same time R seized P's boat, advertised it for sale, and provided P the opportunity to post bond to avoid the sale of P's boat. Subsequently, R mailed a notice of deficiency to P, who immediately petitioned this Court and also moved for a stay of…
2Cases cited6 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- United States v. Mellon Bank, N. A., Appeal of Milton F. Meissner, Intervenor-RespondentCourt of Appeals for the Third Circuit · 1975
- Williams v. CommissionerUnited States Tax Court · 1989
- Omnibus Financial Corp. v. United StatesCourt of Appeals for the Ninth Circuit · 1977
- Hohman v. United StatesDistrict Court, District of Columbia · 1982
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