McWilliams v. Commissioner
United States Tax Court
R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. Pursuant to P's motion made in accordance with sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure, this Court held for petitioner and ordered abatement of the jeopardy assessment and release of the levy.
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R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. Pursuant to P's motion made in accordance with sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure, this Court held for petitioner and ordered abatement of the jeopardy assessment and release of the levy. McWilliams v. Commissioner, 103 T.C. 416 (1994). P filed a motion for attorney's fees and administrative costs pursuant to sec. 7430, I.R.C., and Rule 231, Tax Court Rules of Practice and Procedure. The underlying deficiency proceeding has not yet been decided. Held, disposition of…
1Opinion of the Court
Robert Lee McWilliams, Petitioner v. Commissioner of Internal Revenue, Respondent
McWilliams v. Commissioner
Docket No. 4651-92
United States Tax Court
104 T.C. 320; 1995 U.S. Tax Ct. LEXIS 16; 104 T.C. No. 13;
March 20, 1995, Filed
R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. Pursuant to P's motion made in accordance with sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure, this Court held for petitioner and ordered abatement of the jeopardy assessment and release of the levy. McWilliams v. Commissioner, 103 T.C. 416 (1994). P filed…
2Cases cited16 opinions
- Estate of William Davidson Merchant, Iii, Deceased, Margaret Norling Merchant, Administrator v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
- Loretto v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- Haskin v. United StatesDistrict Court, C.D. California · 1977
- Bobbie J. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Groetzinger v. CommissionerUnited States Tax Court · 1986
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