Harris v. Commissioner
United States Tax Court
Jurisdiction -- Bankruptcy -- Treasury Regulations -- Sec. 274(a), I.R.C. 1939. -- Petitions filed before, not after, the adjudication of bankruptcy or the appointment of a receiver give the Tax Court jurisdiction. Regulations 118, section 39.274-1(b), were not intended to and cannot limit jurisdiction of the Tax Court to proceedings initiated by petitions filed with the Tax Court before bankruptcy petitions were filed.
1Opinion of the Court
Bucky Harris, Transferee of Assets of Harman Steel Corporation, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Harris v. Commissioner
Docket Nos. 64580, 64581, 64582, 64583, 64584
United States Tax Court
32 T.C. 1216; 1959 U.S. Tax Ct. LEXIS 85;
September 22, 1959, Filed
Jurisdiction -- Bankruptcy -- Treasury Regulations -- Sec. 274(a), I.R.C. 1939. -- Petitions filed before, not after, the adjudication of bankruptcy or the appointment of a receiver give the Tax Court jurisdiction. Regulations 118, section 39.274-1(b), were not intended to and cannot limit jurisdiction of…
2Cases cited5 opinions
- Comas, Inc. v. CommissionerUnited States Tax Court · 1954
- Plains Buying & Selling Asso. v. CommissionerUnited States Board of Tax Appeals · 1927
- Missouri P. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Molly--'es Doll-outfitters, Inc. v. CommissionerUnited States Board of Tax Appeals · 1938
- Harris v. CommissionerUnited States Tax Court · 1959