Ross v. Commissioner
United States Tax Court
The respondent on June 21, 1961, made a jeopardy assessment against the petitioner under section 6861 of the 1954 Code; on July 28, 1961, the United States District Court pursuant to section 7403(d) appointed a receiver for the petitioner's United States properties; on August 17, 1961, the respondent mailed a notice of deficiency to the petitioner; and on January 10, 1962, a petition was filed in this Court.
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The respondent on June 21, 1961, made a jeopardy assessment against the petitioner under section 6861 of the 1954 Code; on July 28, 1961, the United States District Court pursuant to section 7403(d) appointed a receiver for the petitioner's United States properties; on August 17, 1961, the respondent mailed a notice of deficiency to the petitioner; and on January 10, 1962, a petition was filed in this Court. Held, the respondent's motion to dismiss for lack of jurisdiction is granted.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The Commissioner on February 23, 1962, filed a motion to dismiss this proceeding for lack of jurisdiction. ' Oral argument was had on the motion and briefs and memoranda have been submitted by the parties.
No disagreement appears as to the facts. On June 21, 1961, the respondent made jeopardy assessment against the petitioner under section 6861(a) of the 1954 Code of deficiencies in income tax, additions to tax, and interest, aggregating $2,224,675.85 for 1956, 1957, .1958, and 1959. On June 29, 1961, after notice of demand for payment, which was refused, the United…
2Cases cited4 opinions
- Bowers v. New York & Albany Lighterage Co.Supreme Court of the United States · 1927
- United States v. Leon I Ross, and Ross & Company, Limited, and Central Trading, Inc.Court of Appeals for the Second Circuit · 1962
- Financial & Industrial Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Pink v. CommissionerUnited States Board of Tax Appeals · 1938
3Cited by17 opinions
- King v. CommissionerUnited States Tax Court · 1969
- Jamy Corporation, a California Corporation v. Robert A. Riddell, Individually and as District Director of Internal Revenue, Los Angeles, CaliforniaCourt of Appeals for the Ninth Circuit · 1964
- Izen v. CommissionerUnited States Tax Court · 1975
- Williams v. CommissionerUnited States Tax Court · 1965
- Pollen v. CommissionerUnited States Tax Court · 1975
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