Matut v. Commissioner
United States Tax Court
Petitioner Albert Matut was in possession of $ 175,000, the ownership of which he denied and apparently claimed belonged to Mario Lignarolo. Pursuant to sec. 6867, I.R.C. 1954, a termination assessment was made against Matut with respect to his possession of the money and, pursuant to sec. 6851(b), a statutory notice of deficiency was issued to him in his capacity as possessor of certain cash.
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Petitioner Albert Matut was in possession of $ 175,000, the ownership of which he denied and apparently claimed belonged to Mario Lignarolo. Pursuant to sec. 6867, I.R.C. 1954, a termination assessment was made against Matut with respect to his possession of the money and, pursuant to sec. 6851(b), a statutory notice of deficiency was issued to him in his capacity as possessor of certain cash. Albert Matut petitioned the Court, both in his individual capacity and in his capacity as possessor of certain cash, for a redetermination of the deficiency. Held, this Court lacks jurisdiction over…
1Opinion of the Court
Albert Matut, as Possessor of Certain Cash, Petitioner v. Commissioner of Internal Revenue, Respondent
Matut v. Commissioner
Docket No. 32639-84
United States Tax Court
84 T.C. 803; 1985 U.S. Tax Ct. LEXIS 85; 84 T.C. No. 53;
May 2, 1985; As Amended May 7, 1985 May 2, 1985, Filed
Petitioner Albert Matut was in possession of $ 175,000, the ownership of which he denied and apparently claimed belonged to Mario Lignarolo. Pursuant to sec. 6867, I.R.C. 1954, a termination assessment was made against Matut with respect to his possession of the money and, pursuant to sec. 6851(b), a statutory notice of…
2Cases cited6 opinions
- Sampson v. CommissionerUnited States Tax Court · 1983
- Cincinnati Transit, Inc. v. CommissionerUnited States Tax Court · 1971
- Cincinnati Transit, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
- Guarino v. CommissionerUnited States Tax Court · 1976
- Estate of Siegel v. CommissionerUnited States Tax Court · 1977
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