Terry v. Commissioner
United States Tax Court
Held, respondent's intercept of petitioner's claim for refund of tax overpayment pursuant to the tax-intercept provisions of sec. 6402(c), I.R.C. 1954, does not foreclose a subsequent determination of a deficiency in petitioner's tax for the same taxable year.
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case was assigned to Special Trial Judge James M. Gussis pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GUSSIS, Special Trial Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for 1984 in the amount of $705. The issue is whether respondent’s intercept (under section 6402(c)) of petitioner’s claimed overpayment of his 1984 tax affects…
2Cases cited4 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Sorenson v. Secretary of the TreasurySupreme Court of the United States · 1986
- Owens v. CommissionerUnited States Tax Court · 1968
- Clark v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946
3Cited by15 opinions
- Savage v. CommissionerUnited States Tax Court · 1999
- Dover Corporation & Subsidiaries, Pathway Bellows, Inc. & Subsidiary, and Measurement Systems, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- Bocock v. Comm'rUnited States Tax Court · 2006
- Abeson v. CommissionerUnited States Tax Court · 1990
- Bocock v. Comm'rUnited States Tax Court · 2006
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