Barnes Theatre Ticket Service, Inc. v. Commissioner
United States Tax Court
The petitioners claim to own substantial real estate and accordingly request that an appeal bond be fixed at 25 percent of the deficiency determined by the Tax Court. Held: To warrant a reduction in the customary amount of an appeal bond the petitioners must furnish security which assures the Internal Revenue Service it can collect any deficiency plus interest ultimately approved by the appellate courts.
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The petitioners claim to own substantial real estate and accordingly request that an appeal bond be fixed at 25 percent of the deficiency determined by the Tax Court. Held: To warrant a reduction in the customary amount of an appeal bond the petitioners must furnish security which assures the Internal Revenue Service it can collect any deficiency plus interest ultimately approved by the appellate courts. Under the circumstances in this case, the petitioners have failed to provide such security.
1Opinion of the Court
OPINION
Simpson, Judge:
On December 18, 1967, this Court’s opinion was filed in this case, and on February 12, 1968, the decision was entered. This proceeding results from a motion by the petitioners in which they indicate their intention to petition for the review of the Court’s decision and request that the amount of the appeal bond be fixed at 25 percent of the deficiency of $147,512.08 determined by this Court.
The petitioners rest their request on the allegation that to purchase an appeal bond in the full amount would impose an unnecessary hardship upon them. They claim that they own real…
2Cited by14 opinions
- Akers v. United StatesDistrict Court, D. Connecticut · 1982
- Estate of Kahn v. CommissionerUnited States Tax Court · 1973
- Adolph Coors Co. v. CommissionerUnited States Tax Court · 1974
- Harwood v. CommissionerUnited States Tax Court · 1984
- Armstrong v. CommissionerUnited States Tax Court · 1992
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