Papa v. Commissioner
United States Tax Court
Held, respondent's computations under Rule 50 adopted. Held, further, no jurisdiction to determine postassessment interest on jeopardy assessments.
1Opinion of the Court
opinion
Irwin, Judge:
On July 24, 1970, respondent filed computations in these dockets under Eule 50, in 'accordance with our Memorandum Findings of Fact and Opinion filed April 22, 1970, T.C. Memo 1970-90. On August 20,1970, petitioners filed alternative computations. Subsequently, two hearings were held and briefs were submitted by the parties in support of their respective positions.
By way of background, we had held in the aforementioned opinion that there are deficiencies for the years 1954,1957,1958, and 1959 with fraud penalties.
On June 22, 1962, respondent made jeopardy assessments…
2Cases cited5 opinions
- Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- COMMISSIONER OF INT. REVENUE v. Kilpatrick's EstateCourt of Appeals for the Sixth Circuit · 1944
- Shedd v. CommissionerUnited States Tax Court · 1961
- Hudgins v. CommissionerUnited States Tax Court · 1970
- Riss & Co. v. CommissionerUnited States Tax Court · 1965
3Cited by9 opinions
- Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
- 508 Clinton St. Corp. v. CommissionerUnited States Tax Court · 1987
- 508 Clinton St. Corp. v. CommissionerUnited States Tax Court · 1987
- Benson v. CommissionerUnited States Tax Court · 1985
- Boyer v. CommissionerUnited States Tax Court · 1994
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