Williams v. Commissioner
United States Tax Court
Jurisdiction -- Sec. 6871. -- Petitioner made an assignment for the benefit of her creditors. The assignee in 1961 brought an action in a State court in Kentucky to settle the estate and liquidated the assets under supervision of that court. In 1962 respondent determined deficiencies and made a jeopardy assessment. Petitioner filed a petition with the Tax Court.
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Jurisdiction -- Sec. 6871. -- Petitioner made an assignment for the benefit of her creditors. The assignee in 1961 brought an action in a State court in Kentucky to settle the estate and liquidated the assets under supervision of that court. In 1962 respondent determined deficiencies and made a jeopardy assessment. Petitioner filed a petition with the Tax Court. Held, the assignment and proceedings pursuant thereto were the equivalent of the appointment of a receiver in a receivership proceeding in a State court and the filing thereafter of the petition with the Tax Court is prohibited by…
1Opinion of the Court
Ruby M. Williams and Charles R. Coy, Assignee of Ruby M. Williams for the Benefit of Creditors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Williams v. Commissioner
Docket No. 3880-62
United States Tax Court
44 T.C. 673; 1965 U.S. Tax Ct. LEXIS 44;
July 30, 1965, Filed
An order of dismissal will be entered.
Jurisdiction -- Sec. 6871. -- Petitioner made an assignment for the benefit of her creditors. The assignee in 1961 brought an action in a State court in Kentucky to settle the estate and liquidated the assets under supervision of that court. In 1962 respondent determined…
2Cases cited11 opinions
- In Re American Fuel & Power Co.Court of Appeals for the Sixth Circuit · 1945
- Comas, Inc. v. CommissionerUnited States Tax Court · 1954
- BancoKentucky Co.'s Receiver v. National Bank of Kentucky's ReceiverCourt of Appeals of Kentucky (pre-1976) · 1939
- Ross v. CommissionerUnited States Tax Court · 1962
- Psaty & Fuhrman, Inc. v. StimsonUnited States Tax Court · 1948
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