Armstrong v. Commissioner
United States Tax Court
P timely submitted a notice of appeal of this Court's order of dismissal for lack of jurisdiction to the U.S. Court of Appeals for the Tenth Circuit, and concurrently filed a motion to accept a surety bond which is double the amount of R's determined deficiency. R objected to P's motion and requested that the bond not be accepted.
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P timely submitted a notice of appeal of this Court's order of dismissal for lack of jurisdiction to the U.S. Court of Appeals for the Tenth Circuit, and concurrently filed a motion to accept a surety bond which is double the amount of R's determined deficiency. R objected to P's motion and requested that the bond not be accepted. Held, pursuant to the provisions of sec. 7485(a)(1), I.R.C., P's motion to accept the bond, where there has been a dismissal for lack of jurisdiction, will be granted.
1Opinion of the Court
William D. Armstrong, Petitioner v. Commissioner of Internal Revenue, Respondent
Armstrong v. Commissioner
Docket No. 19408-91
United States Tax Court
99 T.C. 506; 1992 U.S. Tax Ct. LEXIS 80; 99 T.C. No. 26;
October 22, 1992, Filed
An appropriate order will be issued.
P timely submitted a notice of appeal of this Court's order of dismissal for lack of jurisdiction to the U.S. Court of Appeals for the Tenth Circuit, and concurrently filed a motion to accept a surety bond which is double the amount of R's determined deficiency. R objected to P's motion and requested that the bond not be accepted.…
2Cases cited10 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Palermo v. United StatesSupreme Court of the United States · 1959
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- White v. United StatesSupreme Court of the United States · 1938
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
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