Romano v. Commissioner
United States Tax Court
On Nov. 17, 1983, U.S. Customs agents seized $ 359,500 in cash from P as he and his wife were attempting to enter Canada from the United States. On the same day, R made a termination assessment against P under sec. 6851, I.R.C.
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On Nov. 17, 1983, U.S. Customs agents seized $ 359,500 in cash from P as he and his wife were attempting to enter Canada from the United States. On the same day, R made a termination assessment against P under sec. 6851, I.R.C. On Oct. 11, 1984, after P failed to file an income tax return, R mailed P a notice of deficiency for P's 1983 taxable year, which P timely petitioned to this Court on Jan. 9, 1985. The proceedings in this Court were stayed pending a criminal tax evasion charge being prosecuted against P and a forfeiture proceeding against the seized funds. R brought suit in U.S.…
1Opinion of the Court
Benedetto Romano, Petitioner v. Commissioner of Internal Revenue, Respondent
Romano v. Commissioner
Docket No. 621-85
United States Tax Court
101 T.C. 530; 1993 U.S. Tax Ct. LEXIS 78; 101 T.C. No. 35;
December 13, 1993, Filed
An appropriate order will be issued.
On Nov. 17, 1983, U.S. Customs agents seized $ 359,500 in cash from P as he and his wife were attempting to enter Canada from the United States. On the same day, R made a termination assessment against P under sec. 6851, I.R.C. On Oct. 11, 1984, after P failed to file an income tax return, R mailed P a notice of deficiency for P's 1983…
2Cases cited10 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Naftel v. CommissionerUnited States Tax Court · 1985
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Laing v. United StatesSupreme Court of the United States · 1976
- Marshall v. CommissionerUnited States Tax Court · 1985
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