Legal Opinion
Commissioner of Internal Revenue, Petitioner-Cross-Respondent v. Leon E. Hendrickson, Respondent-Cross-Petitioner, and Peoples Loan & Trust Company
Court of Appeals for the Seventh Circuit
Decided April 27, 1989No. 88-1208, 88-1209, 88-1421, 88-1422PublishedCited by 17 opinions
1Opinion of the Court
POSNER, Circuit Judge.
When the Internal Revenue Service believes that a taxpayer intends to leave (or remove his property from) the country, conceal himself or his property, become insolvent, or do or suffer anything else that might thwart efforts to collect taxes due from him, it can make an immediate determination of his tax liability — that is, without waiting until the end of the taxpayer’s tax year — and demand immediate payment of the taxes due. 26 U.S.C. § 6851(a)(1). These are “termination assessments.” Similarly, when the Service believes that collection of a tax deficiency would be…
2Cases cited12 opinions
- Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
- Louis Buddy Yosha v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Commissioner v. BollingerSupreme Court of the United States · 1988
- Vukasovich, Inc. v. Commissioner of Internal Revenue, Vukasovich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Refrigeration Sales Co., Inc. v. Mitchell-Jackson, Inc., a Corporation, and Alfred L. JacksonCourt of Appeals for the Seventh Circuit · 1985
7 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
- Cabintaxi Corporation, Formerly Known as Automated Transit, Incorporated, and Robert Edler, "Tax Matters Person," v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1995
- H. Dale Gunther and Marie M. Gunther v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1990
- Charles E. Shepherd v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1998
- Larson v. United StatesUnited States Court of Federal Claims · 2009
12 more not listed; retrieve them via the Exa API.