Prince v. Comm'r
United States Tax Court
To collect P's 1997, 1998, 1999, and 2002 unpaid income tax liabilities and additions to tax discharged in P's 2005 bankruptcy filing, R served a notice of jeopardy levy on the Los Angeles County District Attorney's Office with respect to funds that the Los Angeles Police Department had seized from P before the bankruptcy on suspicion of fraudulent credit card transactions. Held: P cannot raise third-party claims in a lien or levy case.
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To collect P's 1997, 1998, 1999, and 2002 unpaid income tax liabilities and additions to tax discharged in P's 2005 bankruptcy filing, R served a notice of jeopardy levy on the Los Angeles County District Attorney's Office with respect to funds that the Los Angeles Police Department had seized from P before the bankruptcy on suspicion of fraudulent credit card transactions. Held: P cannot raise third-party claims in a lien or levy case. Held, further, jeopardy levy is proper here where funds belong to P's prebankruptcy estate and are subject to a prebankruptcy lien filed by R.
1Opinion of the Court
JIMMY ASIEGBU PRINCE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Prince v. Comm'r
No. 13858-08L
United States Tax Court
133 T.C. 270; 2009 U.S. Tax Ct. LEXIS 32; 133 T.C. No. 12;
November 2, 2009, Filed
Prince v. Comm'r, T.C. Memo 2003-247, 2003 Tax Ct. Memo LEXIS 247 (T.C., 2003)
To collect P's 1997, 1998, 1999, and 2002 unpaid income tax liabilities and additions to tax discharged in P's 2005 bankruptcy filing, R served a notice of jeopardy levy on the Los Angeles County District Attorney's Office with respect to funds that the Los Angeles Police Department had seized from P before…
2Cases cited16 opinions
- Warth v. SeldinSupreme Court of the United States · 1975
- Valley Forge Christian College v. Americans United for Separation of Church and State, Inc.Supreme Court of the United States · 1982
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
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