Pollock v. Comm'r
United States Tax Court
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
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- Bowen v. City of New YorkSupreme Court of the United States · 1986
- Zipes v. Trans World Airlines, Inc.Supreme Court of the United States · 1982
- Christianson v. Colt Industries Operating Corp.Supreme Court of the United States · 1988
- Arizona v. CaliforniaSupreme Court of the United States · 1983
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