Gaw v. Commissioner
United States Tax Court
R imposed a jeopardy assessment on Ps under authority of sec. 6861, I.R.C. Ps requested an administrative review of the jeopardy assessment on the grounds that such assessment was unreasonable. R upheld the jeopardy assessment. Ps filed a motion for review of the jeopardy assessment with this Court pursuant to sec. 7429(b) (2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure.
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R imposed a jeopardy assessment on Ps under authority of sec. 6861, I.R.C. Ps requested an administrative review of the jeopardy assessment on the grounds that such assessment was unreasonable. R upheld the jeopardy assessment. Ps filed a motion for review of the jeopardy assessment with this Court pursuant to sec. 7429(b) (2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure. We are required to make a de novo determination within 20 days from the filing of a motion to review as to two issues: (1) Whether the making of the jeopardy assessment is reasonable under the…
1Opinion of the Court
ANTHONY TEONG-CHAN GAW AND ROSANNA W. GAW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gaw v. Commissioner
Docket No. 8015-92.
United States Tax Court
T.C. Memo 1995-373; 1995 Tax Ct. Memo LEXIS 377; 70 T.C.M. (CCH) 336;
August 8, 1995, Filed
R imposed a jeopardy assessment on Ps under authority of sec. 6861, I.R.C. Ps requested an administrative review of the jeopardy assessment on the grounds that such assessment was unreasonable. R upheld the jeopardy assessment. Ps filed a motion for review of the jeopardy assessment with this Court pursuant to sec. 7429(b) (2), I.R.C., and Rule…
2Cases cited5 opinions
- Loretto v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- Anthony Teong-Chan Gaw Rossana W. Gaw v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1995
- Revis v. United StatesDistrict Court, D. Rhode Island · 1983
- Bean v. United StatesDistrict Court, N.D. Georgia · 1985
- McWilliams v. CommissionerUnited States Tax Court · 1994