Miravalle v. Commissioner
United States Tax Court
R, believing collection of any tax that may be due from Ps to be in jeopardy, made a jeopardy assessment and seized Ps' realty. R thereafter issued a notice of deficiency, and Ps filed a petition contesting R's determination. After the jeopardy assessment, seizure, and our acquisition of jurisdiction, a local taxing authority enforced its real estate tax claim against the property.
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R, believing collection of any tax that may be due from Ps to be in jeopardy, made a jeopardy assessment and seized Ps' realty. R thereafter issued a notice of deficiency, and Ps filed a petition contesting R's determination. After the jeopardy assessment, seizure, and our acquisition of jurisdiction, a local taxing authority enforced its real estate tax claim against the property. Thereafter, an unrelated third party purchased the realty through a local government sale to satisfy unpaid real estate tax. R, under sec. 7425, I.R.C., redeemed the property, resulting in R's securing title to the…
1Opinion of the Court
DONALD J. MIRAVALLE AND LILLIAN JOY MIRAVALLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Miravalle v. Commissioner
Docket Nos. 9870-91, 7251-93, 10686-94
United States Tax Court
105 T.C. 65; 1995 U.S. Tax Ct. LEXIS 42; 105 T.C. No. 5;
July 31, 1995, Filed
R, believing collection of any tax that may be due from Ps to be in jeopardy, made a jeopardy assessment and seized Ps' realty. R thereafter issued a notice of deficiency, and Ps filed a petition contesting R's determination. After the jeopardy assessment, seizure, and our acquisition of jurisdiction, a local taxing authority…
2Cases cited7 opinions
- Southern Bank of Lauderdale County v. Internal Revenue Service, United States of America, Mid-State Homes, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- Williams v. CommissionerUnited States Tax Court · 1989
- Galusha v. CommissionerUnited States Tax Court · 1990
- United States v. Marion County, Fla.District Court, M.D. Florida · 1993
- Miravalle v. CommissionerUnited States Tax Court · 1995
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