Legal Opinion
Transport Manufacturing & Equipment Company (A Delaware Corporation) Transferee v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided August 10, 1973No. 72-1508PublishedCited by 8 opinions
1Opinion of the Court
LAY, Circuit Judge.
This appeal relating to a 1960 jeopardy assessment filed against the Transport Manufacturing & Equipment Company of Delaware (TM&E) reaches our court for the third time. Originally the taxpayer sought relief to compel the Commissioner to abate the jeopardy assessment upon tender of the balance due under the deficiency assessment. 1 The tender did not include any post-assessment interest, and the Commissioner refused to withdraw the assessment. The district court dismissed this action, and we affirmed for lack of jurisdiction under Section 7421 of the 1954 Code. Transport…
2Cases cited15 opinions
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- United States Ex Rel. Girard Trust Co. v. HelveringSupreme Court of the United States · 1937
- Stein v. CommissionerUnited States Tax Court · 1962
- Herbert F. Lessmann and Mildred Lessmann v. Commissioner of Internal Revenue, Herbert F. Lessmann v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Lowy v. CommissionerUnited States Tax Court · 1960
10 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Continental Equities, Inc., Cross-Appellant v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Paul F. Belloff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Melva Shanker v. United StatesCourt of Appeals for the Eighth Circuit · 1978
- Estate of Bender v. CommissionerUnited States Tax Court · 1986
- Malone & Hyde, Inc.United States Tax Court · 1992
3 more not listed; retrieve them via the Exa API.