Poinier v. Commissioner
United States Tax Court
On motion by Ps to reduce the amount of a surety bond filed in respect of the appeal of our decisions entered in accordance with our opinion in Poinier v. Commissioner, 86 T.C. 478 (1986), affd. in part and revd. in part 858 F.2d 917 (3d Cir. 1988), held: 1. This Court has jurisdiction to reduce the amount of the bond even though decisions in the above-docketed cases have become final. 2. The surety bond is reduced by payments made subsequent to the filing of the bond and in…
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On motion by Ps to reduce the amount of a surety bond filed in respect of the appeal of our decisions entered in accordance with our opinion in Poinier v. Commissioner, 86 T.C. 478 (1986), affd. in part and revd. in part 858 F.2d 917 (3d Cir. 1988), held: 1. This Court has jurisdiction to reduce the amount of the bond even though decisions in the above-docketed cases have become final. 2. The surety bond is reduced by payments made subsequent to the filing of the bond and in respect of a refund due petitioner W. Page Wodell but not in respect of other amounts claimed by Ps. 3. Under the…
1Opinion of the Court
OPINION
TANNENWALD, Judge:
This case is again before us on a motion by petitioners to release and modify the surety bond secured by a letter of credit filed by petitioners pursuant to our opinion in Pointer v. Commissioner, 90 T.C. 63 (1988), in connection with their appeal from our decisions in Poinier v. Commissioner, 86 T.C. 478 (1986), entered in all three dockets on August 24, 1987. Our decision in docket No. 23883-81 was affirmed and our decisions in docket Nos. 23881-81 and 23882-81 were affirmed in part and reversed in part by the U.S. Court of Appeals for the Third Circuit on September…
2Cases cited5 opinions
- Poinier v. CommissionerUnited States Tax Court · 1986
- Estate of Kahn v. CommissionerUnited States Tax Court · 1973
- Estate of Halbach v. CommissionerUnited States Tax Court · 1978
- Estate of Schneider v. CommissionerUnited States Tax Court · 1989
- Poinier v. CommissionerUnited States Tax Court · 1988
3Cited by1 opinion
- Poinier v. CommissionerUnited States Tax Court · 1991