Legal Opinion

Pollock v. Comm'r

United States Tax Court

Decided February 12, 2009No. 17755-07Published

P sought relief from joint liability for unpaid taxes under sec. 6015, I.R.C. R sent her a notice of determination denying relief, but at a time before Congress gave the Tax Court jurisdiction to review such denials. R then sought to collect the taxes in a lien-enforcement action. This prompted the District Court hearing the lien-enforcement action to invoke the doctrine of equitable tolling and give P 30 days to file a petition with the Tax Court.

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P sought relief from joint liability for unpaid taxes under sec. 6015, I.R.C. R sent her a notice of determination denying relief, but at a time before Congress gave the Tax Court jurisdiction to review such denials. R then sought to collect the taxes in a lien-enforcement action. This prompted the District Court hearing the lien-enforcement action to invoke the doctrine of equitable tolling and give P 30 days to file a petition with the Tax Court. P filed her petition within the time limit set by the District Court's order. R moved to dismiss for lack of jurisdiction because P filed her…

1Opinion of the Court

ARLENE L. POLLOCK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Pollock v. Comm'r

No. 17755-07

United States Tax Court

132 T.C. 21; 2009 U.S. Tax Ct. LEXIS 3; 132 T.C. No. 3;

February 12, 2009, Filed

P sought relief from joint liability for unpaid taxes under sec. 6015, I.R.C. R sent her a notice of determination denying relief, but at a time before Congress gave the Tax Court jurisdiction to review such denials. R then sought to collect the taxes in a lien-enforcement action. This prompted the District Court hearing the lien-enforcement action to invoke the doctrine of equitable…

2Cases cited55 opinions

  1. Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
  2. Bowen v. City of New YorkSupreme Court of the United States · 1986
  3. Zipes v. Trans World Airlines, Inc.Supreme Court of the United States · 1982
  4. Christianson v. Colt Industries Operating Corp.Supreme Court of the United States · 1988
  5. Arizona v. CaliforniaSupreme Court of the United States · 1983

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