Estate of Kahn v. Commissioner
United States Tax Court
This Court entered a decision finding deficiencies in income tax and additions to tax under the provisions of sec. 6653(b), I.R.C. 1954, against petitioners aggregating $ 963,490.90. In seeking review of our decision petitioners contend that the maximum limitation on the amount of the bond to stay assessment and collection pending review should be double the amount of the deficiency in income tax only, instead of double the amount of the deficiency in tax and addition to tax…
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This Court entered a decision finding deficiencies in income tax and additions to tax under the provisions of sec. 6653(b), I.R.C. 1954, against petitioners aggregating $ 963,490.90. In seeking review of our decision petitioners contend that the maximum limitation on the amount of the bond to stay assessment and collection pending review should be double the amount of the deficiency in income tax only, instead of double the amount of the deficiency in tax and addition to tax and, further, that the Court should accept corporate securities and a promissory note in lieu of a surety on the bond.…
1Opinion of the Court
OPINION
Goffe, Judge:
On June 27, 1973, this Court entered a decision pursuant to our opinion filed on December 4,1972. Petitioners have filed a motion to approve a bond to stay assessment and collection pending review of our opinion by the U.S. Court of Appeals, such bond to be secured by collateral instead of a surety.
In our decision we determined deficiencies in income tax due from petitioners for the taxable years 1956, 1957, and 1958 aggregating $618,746.62, and additions to the tax under the provisions of section 6653(b) of the Code1 due from petitioners aggregating $344,744.28.
Petitioners…
2Cases cited3 opinions
- Burns, Stix Friedman & Co. v. CommissionerUnited States Tax Court · 1971
- Trans World Airlines, Inc. v. HughesDistrict Court, S.D. New York · 1970
- Barnes Theatre Ticket Service, Inc. v. CommissionerUnited States Tax Court · 1968
3Cited by14 opinions
- Adolph Coors Co. v. CommissionerUnited States Tax Court · 1974
- Estate of Schneider v. CommissionerUnited States Tax Court · 1989
- Poinier v. CommissionerUnited States Tax Court · 1988
- Jacobson v. CommissionerUnited States Tax Court · 1991
- Freesen v. CommissionerUnited States Tax Court · 1987
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