Miravalle v. Commissioner
United States Tax Court
R, believing collection of any tax that may be due from Ps to be in jeopardy, made a jeopardy assessment and seized Ps' realty. R thereafter issued a notice of deficiency, and Ps filed a petition contesting R's determination. After the jeopardy assessment, seizure, and our acquisition of jurisdiction, a local taxing authority enforced its real estate tax claim against the property.
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R, believing collection of any tax that may be due from Ps to be in jeopardy, made a jeopardy assessment and seized Ps' realty. R thereafter issued a notice of deficiency, and Ps filed a petition contesting R's determination. After the jeopardy assessment, seizure, and our acquisition of jurisdiction, a local taxing authority enforced its real estate tax claim against the property. Thereafter, an unrelated third party purchased the realty through a local government sale to satisfy unpaid real estate tax. R, under sec. 7425, I.R.C., redeemed the property, resulting in R's securing title to the…
1Opinion of the Court
OPINION
Gerber, Judge:
Petitioners moved to stay respondent’s sale of property. We consider whether the provisions of section 68631 would grant us jurisdiction to stay the sale.
Background
Respondent made jeopardy assessments of and issued a notice of deficiency for deficiencies in petitioners’ income tax for 1984, 1985, and 1986 tax years. Shortly after making the jeopardy assessments in December 1990, respondent seized petitioners’ real property, commonly known as Pinellas Center, lots 11 and 12 (Pinellas realty). Petitioners filed a petition with this Court, and we acquired jurisdiction of the…
2Cases cited5 opinions
- Southern Bank of Lauderdale County v. Internal Revenue Service, United States of America, Mid-State Homes, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- Williams v. CommissionerUnited States Tax Court · 1989
- Galusha v. CommissionerUnited States Tax Court · 1990
- United States v. Marion County, Fla.District Court, M.D. Florida · 1993
- Miravalle v. CommissionerUnited States Tax Court · 1995
3Cited by1 opinion
- Miravalle v. CommissionerUnited States Tax Court · 1995