Hefti v. Commissioner
United States Tax Court
Respondent served a third-party administrative summons on petitioners' bank. Pursuant to sec. 7609(b)(2) petitioners filed in the district court a petition to quash the summons. The district court dismissed the petition and petitioners did not appeal but prior to the expiration of the appeal period the bank fully complied with the summons. The bank's compliance with the summons occurred 205 days after the filing of the petition to quash the summons.
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Respondent served a third-party administrative summons on petitioners' bank. Pursuant to sec. 7609(b)(2) petitioners filed in the district court a petition to quash the summons. The district court dismissed the petition and petitioners did not appeal but prior to the expiration of the appeal period the bank fully complied with the summons. The bank's compliance with the summons occurred 205 days after the filing of the petition to quash the summons. The period for appeal of the district court's dismissal of the petition expired 244 days after the filing of the petition. Respondent's…
1Opinion of the Court
SUPPLEMENTAL OPINION
SHIELDS, Judge:
This case was remanded by the Court of Appeals for the Eighth Circuit for consideration by us of section 301.7609-5(b), Proced. & Admin. Regs., vis-á-vis the suspension under section 7609(e)1 of the period of limitations provided by section 6501(a).
On April 15, 1984, petitioners filed with the Internal Revenue Service (IRS) a joint Federal income tax return for
1983. On October 10, 1986, respondent served a third-party summons on the Landmark Bank of St. Louis, Missouri, in which the bank was directed to produce for examination by respondent’s agents all…
2Cases cited44 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Burnet v. HarmelSupreme Court of the United States · 1932
- Donaldson v. United StatesSupreme Court of the United States · 1971
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
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3Cited by36 opinions
- Greene-Thapedi v. Comm'rUnited States Tax Court · 2006
- Charles Hefti Marion Hefti v. Commissioner of Internal Revenue of the United States of AmericaCourt of Appeals for the Eighth Circuit · 1993
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Western Nat'l Mut. Ins. Co. v. CommissionerUnited States Tax Court · 1994
- Tutor-Saliba Corp. v. CommissionerUnited States Tax Court · 2000
31 more not listed; retrieve them via the Exa API.