Legal Opinion

Williams v. Commissioner

United States Tax Court

Decided May 9, 1989No. Docket Nos. 28141-87, 28142-87Published

Petitioners seek review under sec. 6863(b)(3)(C), I.R.C. 1986, of respondent's determination to sell property (jewelry and furs) seized from petitioners. The issue for decision is the propriety of respondent's determination to sell the property.

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Petitioners seek review under sec. 6863(b)(3)(C), I.R.C. 1986, of respondent's determination to sell property (jewelry and furs) seized from petitioners. The issue for decision is the propriety of respondent's determination to sell the property. Respondent's decision to sell was based on a determination that the property is "liable to become greatly reduced in value" (sec. 6336). Held: 1. The Court has jurisdiction to act on the motion. 2. The Court may issue a temporary stay of the sale of assets seized pursuant to a jeopardy or termination assessment pending review. 3. Issuance of a…

1Opinion of the Court

Melvin Williams and Mary Williams, Petitioners v. Commissioner of Internal Revenue, Respondent; Melvin Williams, Petitioner v. Commissioner of Internal Revenue, Respondent

Williams v. Commissioner

Docket Nos. 28141-87, 28142-87

United States Tax Court

92 T.C. 920; 1989 U.S. Tax Ct. LEXIS 63; 92 T.C. No. 58;

May 9, 1989. May 9, 1989, Filed

Petitioners seek review under sec. 6863(b)(3)(C), I.R.C. 1986, of respondent's determination to sell property (jewelry and furs) seized from petitioners. The issue for decision is the propriety of respondent's determination to sell the property. Respondent's…

2Cases cited28 opinions

  1. Link v. Wabash RailroadSupreme Court of the United States · 1962
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. Roadway Express, Inc. v. PiperSupreme Court of the United States · 1980
  4. Bull v. United StatesSupreme Court of the United States · 1935
  5. Miller v. Standard Nut Margarine Co. of Fla.Supreme Court of the United States · 1932

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