Schlosser v. Commissioner
United States Tax Court
Ps moved to restrain the collection of taxes, alleging that the IRS was demanding payment of deficiencies for 1983, 1984, and 1985 prior to a final decision of the Tax Court. R moved to dismiss for lack of jurisdiction as to P-husband based on the automatic stay provisions of the Bankruptcy Code.
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Ps moved to restrain the collection of taxes, alleging that the IRS was demanding payment of deficiencies for 1983, 1984, and 1985 prior to a final decision of the Tax Court. R moved to dismiss for lack of jurisdiction as to P-husband based on the automatic stay provisions of the Bankruptcy Code. Held, R's motion to dismiss for lack of jurisdiction as to P-husband will be granted. 11 U.S.C. sec. 362(a)(8). Held, further, because the collection efforts in question relate in part to overstated withheld income taxes summarily assessed under secs. 6201(a)(3) and 6213(b)(1), I.R.C., and in part to…
1Opinion of the Court
Gabriel Schlosser and Mary Ellen Schlosser, Petitioners v. Commissioner of Internal Revenue, Respondent
Schlosser v. Commissioner
Docket No. 29514-89
United States Tax Court
94 T.C. 816; 1990 U.S. Tax Ct. LEXIS 56; 94 T.C. No. 51;
June 11, 1990, Filed
An order granting respondent's motion for leave to amend his supplemental notice of objection and granting respondent's motion to dismiss for lack of jurisdiction will be issued.
An order denying petitioners' motion to stop collection action will be issued.
Ps moved to restrain the collection of taxes, alleging that the IRS was demanding payment of…
2Cases cited20 opinions
- Laing v. United StatesSupreme Court of the United States · 1976
- Hutchinson v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Judge v. CommissionerUnited States Tax Court · 1987
- Neilson v. CommissionerUnited States Tax Court · 1990
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