Harwood v. Commissioner
United States Tax Court
After an opinion in these cases was filed, 82 T.C. 239 (1984), R submitted computations of deficiencies under Rule 155, Tax Court Rules of Practice and Procedure, together with proposed decisions.
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After an opinion in these cases was filed, 82 T.C. 239 (1984), R submitted computations of deficiencies under Rule 155, Tax Court Rules of Practice and Procedure, together with proposed decisions. Ps did not dispute the amounts computed by R. Rather, they filed a notice of objection and request for hearing, wherein they argued that the Court should determine the acceptability of first deeds of trust on property they owned or controlled in lieu of an appeal bond pursuant to sec. 7485(a)(2), I.R.C. 1954 as amended. Held: Argument under Rule 155 proceedings is strictly limited to consideration…
1Opinion of the Court
OPINION
Cantrel, Special Trial Judge:
These consolidated cases were called from the calendar for the motions session of the Court at Washington, D.C., on October 10,1984, for hearing on respondent’s computation for entry of decision. Counsel for the parties appeared and presented argument.2
On February 8,1984, the Court filed its opinion (82 T.C. 239) in these cases holding that transactions among the petitioners shifting their respective holdings in the family partnership were taxable gifts to the extent the value of the property transferred exceeded the consideration received therefor;…
2Cases cited10 opinions
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- Anthony v. CommissionerUnited States Tax Court · 1976
- Harwood v. CommissionerUnited States Tax Court · 1984
- Florence M. Barnes, and Barnes Theatre Ticket Service, Inc., an Illinois Corporation v. The Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Cloes v. CommissionerUnited States Tax Court · 1982
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Halliburton Co. v. CommissionerUnited States Tax Court · 1992
- Kazi v. CommissionerUnited States Tax Court · 1991
- Litzenberg v. CommissionerUnited States Tax Court · 1988
- Dell v. CommissionerUnited States Tax Court · 1985
- Halliburton Co. v. CommissionerUnited States Tax Court · 1992
2 more not listed; retrieve them via the Exa API.