Legal Opinion

Meyer v. Commissioner

United States Tax Court

Decided November 18, 1991No. Docket No. 9434-90PublishedCited by 47 opinions

Ps filed a motion for an order enjoining R from collection activities. Ps seek to enjoin R from collecting Ps' outstanding income tax liabilities that are based upon assessments not subject to the deficiency procedures of secs. 6211 et seq. of taxes computed and shown due on Ps' delinquently filed original and amended returns for the years 1980 through 1982. Ps also seek to enjoin R from collecting the additions to tax under I.R.C. secs. 6651(a)(1) and 6654 that were…

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Ps filed a motion for an order enjoining R from collection activities. Ps seek to enjoin R from collecting Ps' outstanding income tax liabilities that are based upon assessments not subject to the deficiency procedures of secs. 6211 et seq. of taxes computed and shown due on Ps' delinquently filed original and amended returns for the years 1980 through 1982. Ps also seek to enjoin R from collecting the additions to tax under I.R.C. secs. 6651(a)(1) and 6654 that were included in the deficiency notice and disputed by Ps in their petition. Held, this Court lacks jurisdiction to restrain R from…

1Opinion of the Court

OPINION

NlMS, Chief Judge:

This case is before the Court on petitioners’ motion for an order enjoining respondent from collection activities. (Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the years in issue.)

Background

By statutory notice of deficiency dated February 13, 1990, respondent determined deficiencies in and additions to petitioners’ Federal income tax as follows:

_Additions to tax_

Sec. Sec. Sec. Sec. Sec.

Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(1)(A) 6653(b) 6654

1980 --- --- --- --- $7,967 $159

1981 a$(2,110) --- --- --- 8,896…

2Cases cited6 opinions

  1. White v. CommissionerUnited States Tax Court · 1990
  2. Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
  3. Smith v. CommissionerUnited States Tax Court · 1991
  4. Powell v. CommissionerUnited States Tax Court · 1991
  5. Odend'Hal v. CommissionerUnited States Tax Court · 1990

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

3Cited by47 opinions

  1. Perez v. United StatesCourt of Appeals for the Fifth Circuit · 2002
  2. Krugman v. CommissionerUnited States Tax Court · 1999
  3. Powerstein v. CommissionerUnited States Tax Court · 1992
  4. Frank Tavano v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
  5. Thompson v. CommissionerUnited States Tax Court · 2011

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

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