Stroube v. Comm'r
United States Tax Court
Respondent moves for summary judgment on a procedural issue as to whether petitioners' allegation that a fraud on this Court occurred during the trial of a tax shelter tax deficiency test case may be raised in this collection case under sec. 6320, I.R.C. Petitioners filed a cross-motion for partial summary judgment on this same procedural issue.
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Respondent moves for summary judgment on a procedural issue as to whether petitioners' allegation that a fraud on this Court occurred during the trial of a tax shelter tax deficiency test case may be raised in this collection case under sec. 6320, I.R.C. Petitioners filed a cross-motion for partial summary judgment on this same procedural issue. Held: The typical and proper method to raise an allegation that a fraud on this Court occurred during the trial of a tax deficiency case is by filing a motion to vacate the decision entered in the specific tax deficiency case in which the alleged…
1Opinion of the Court
STEVEN G. AND ELAINE R. STROUBE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Stroube v. Comm'r
No. 12628-07L
United States Tax Court
130 T.C. 257; 2008 U.S. Tax Ct. LEXIS 15; 130 T.C. No. 15;
June 19, 2008, Filed
Respondent moves for summary judgment on a procedural issue as to whether petitioners' allegation that a fraud on this Court occurred during the trial of a tax shelter tax deficiency test case may be raised in this collection case under sec. 6320, I.R.C. Petitioners filed a cross-motion for partial summary judgment on this same procedural issue.
Held: The typical and proper…
2Cases cited7 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Krause v. CommissionerUnited States Tax Court · 1992
- Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
- Vulcan Oil Tech. Partners v. CommissionerUnited States Tax Court · 1998
- Estate of Campion v. CommissionerUnited States Tax Court · 1998
2 more not listed; retrieve them via the Exa API.