Legal Opinion

Pollen v. Commissioner

United States Tax Court

Decided May 21, 1975No. Docket No. 6049-72Published

The Commissioner, on Apr. 13, 1972, made a jeopardy assessment against petitioners; on May 12, 1972, the United States District Court appointed a receiver who qualified on May 25, 1972; on June 9, 1972, the Commissioner mailed a statutory notice of deficiency to petitioners covering the taxable years covered by the jeopardy assessment; and on July 25, 1972, petitioners filed their petition herein for a redetermination of the taxes and additions to tax covered by the…

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The Commissioner, on Apr. 13, 1972, made a jeopardy assessment against petitioners; on May 12, 1972, the United States District Court appointed a receiver who qualified on May 25, 1972; on June 9, 1972, the Commissioner mailed a statutory notice of deficiency to petitioners covering the taxable years covered by the jeopardy assessment; and on July 25, 1972, petitioners filed their petition herein for a redetermination of the taxes and additions to tax covered by the statutory notice of deficiency. Held, respondent's motion to dismiss for lack of jurisdiction is granted. Leon I. Ross, 38 T.C.…

1Opinion of the Court

William Pollen and Bobbie Pollen, Petitioners v. Commissioner of Internal Revenue, Respondent

Pollen v. Commissioner

Docket No. 6049-72

United States Tax Court

64 T.C. 261; 1975 U.S. Tax Ct. LEXIS 143;

May 21, 1975, Filed

The Commissioner, on Apr. 13, 1972, made a jeopardy assessment against petitioners; on May 12, 1972, the United States District Court appointed a receiver who qualified on May 25, 1972; on June 9, 1972, the Commissioner mailed a statutory notice of deficiency to petitioners covering the taxable years covered by the jeopardy assessment; and on July 25, 1972, petitioners filed their…

2Cases cited4 opinions

  1. Fotochrome, Inc. v. CommissionerUnited States Tax Court · 1972
  2. Ross v. CommissionerUnited States Tax Court · 1962
  3. Conlee Constr. Co. v. CommissionerUnited States Tax Court · 1970
  4. Pollen v. CommissionerUnited States Tax Court · 1975

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