Legal Opinion

Jimmy Asiegbu Prince v. Commissioner

United States Tax Court

Decided November 2, 2009No. 13858-08LUnknown

1Opinion of the Court

133 T.C. No. 12

UNITED STATES TAX COURT JIMMY ASIEGBU PRINCE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13858-08L. Filed November 2, 2009. 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…

2Cases cited16 opinions

  1. Warth v. SeldinSupreme Court of the United States · 1975
  2. Valley Forge Christian College v. Americans United for Separation of Church and State, Inc.Supreme Court of the United States · 1982
  3. Goza v. CommissionerUnited States Tax Court · 2000
  4. Sego v. CommissionerUnited States Tax Court · 2000
  5. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994

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