Peoples Loan & Trust Co. v. Commissioner
United States Tax Court
The Court of Appeals for the Seventh Circuit reversed and remanded the opinion of this Court at 89 T.C. 896. In accordance with said remand, it is held that the notices of deficiency in these cases were adequate to give the Court jurisdiction to hear and decide them; further held, that the notice of deficiency in docket No. 30402-84 was in error in that sec. 6867, I.R.C., does not apply to corporations; further held, that the statute did apply to petitioner in docket No.…
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The Court of Appeals for the Seventh Circuit reversed and remanded the opinion of this Court at 89 T.C. 896. In accordance with said remand, it is held that the notices of deficiency in these cases were adequate to give the Court jurisdiction to hear and decide them; further held, that the notice of deficiency in docket No. 30402-84 was in error in that sec. 6867, I.R.C., does not apply to corporations; further held, that the statute did apply to petitioner in docket No. 30420-84. Amounts of deficiency determined.
1Opinion of the Court
PEOPLES LOAN & TRUST CO., AS POSSESSOR OF CERTAIN CASH, Petitioner v. COMMISSIONER OF INTERNAL RZVENUE, Respondent; LEON E. HENDRICKSON, AS POSSESSOR OF CERTAIN CASH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Peoples Loan & Trust Co. v. Commissioner
Docket Nos. 30402-84; 30420-84
United States Tax Court
T.C. Memo 1989-524; 1989 Tax Ct. Memo LEXIS 524; 58 T.C.M. (CCH) 227; T.C.M. (RIA) 89524;
September 26, 1989
The Court of Appeals for the Seventh Circuit reversed and remanded the opinion of this Court at 89 T.C. 896. In accordance with said remand, it is held that the notices of…
2Cases cited9 opinions
- Shelton v. CommissionerUnited States Tax Court · 1974
- Commissioner of Internal Revenue, Petitioner-Cross-Respondent v. Leon E. Hendrickson, Respondent-Cross-Petitioner, and Peoples Loan & Trust CompanyCourt of Appeals for the Seventh Circuit · 1989
- Matut v. CommissionerUnited States Tax Court · 1986
- Matut v. CommissionerUnited States Tax Court · 1987
- California Federal Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
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