Peoples Loan & Trust Co. v. Commissioner
United States Tax Court
M operated NCEA as a membership organization. M accepted deposits from members, acquired precious metals with such funds, and paid such members' bills in cash. M died in 1983. At his death, H, a coin dealer, and PL, a bank, were in possession of precious metals and cash held for M or for his clients. PL was subsequently appointed administrator of M's estate in Indiana.
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M operated NCEA as a membership organization. M accepted deposits from members, acquired precious metals with such funds, and paid such members' bills in cash. M died in 1983. At his death, H, a coin dealer, and PL, a bank, were in possession of precious metals and cash held for M or for his clients. PL was subsequently appointed administrator of M's estate in Indiana. Members of NCEA filed claims against the estate, seeking return of the precious metals purchased by M on their behalf, and N, a bank in Colorado, commenced an action in a Federal court in Indiana seeking to determine the…
1Opinion of the Court
KÓRNER, Judge:
In these consolidated cases, the Commissioner determined that petitioner Peoples Loan & Trust Co., as possessor of certain cash, had a deficiency in Federal income tax of $113,250 for 1983, and that petitioner Leon E. Hendrickson, as possessor of certain cash, had a deficiency in Federal income tax of $1,834,500.25 for 1983. The issue for our decision is whether petitioners are liable for such deficiencies under section 6867 of the Internal Revenue Code of 1954,2 relating to jeopardy assessments against possessors of substantial cash when the owner is unknown.
FINDINGS OF FACT
Some…
2Cases cited9 opinions
- Abrams v. CommissionerUnited States Tax Court · 1984
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Durovic v. CommissionerUnited States Tax Court · 1970
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Shelton v. CommissionerUnited States Tax Court · 1974
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Commissioner of Internal Revenue, Petitioner-Cross-Respondent v. Leon E. Hendrickson, Respondent-Cross-Petitioner, and Peoples Loan & Trust CompanyCourt of Appeals for the Seventh Circuit · 1989
- Casebeer v. CommissionerUnited States Tax Court · 1987
- Keith v. CommissionerUnited States Tax Court · 1989
- Peoples Loan & Trust Co. v. CommissionerUnited States Tax Court · 1987
- Peoples Loan & Trust Co. v. CommissionerUnited States Tax Court · 1989
1 more not listed; retrieve them via the Exa API.