Shapiro v. Commissioner
United States Tax Court
Held, petitioners are not entitled to an order directing respondent to release funds subject to a lien of a jeopardy assessment in order to pay fees to counsel for representation in the above-docketed cases.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent has asserted deficiencies in petitioners’ income taxes as follows:
Additions to tax
Deficiency Delinquency Negligence Underestimation of tax
Docket No. Year of tax (Sec. 6651(a))1 (Sec. 6653(a)) (Sec. 6651(a))
178-74 1970 $5,137.89 $1,284.47 $256.90 $164.42
1971 79,368.50 3,968.43
Deficiency Addition to tax — fraud Diability of Bella Shapiro Docket No. Year of tax (Sec. 6653(b)) limited to deficiency of tax
6489-76 1972 $22,562.63 $11,281.31 $22,562.63
1973 136,578.10 68,289.05 136,578.10
Respondent also, on December 6, 1973, issued a jeopardy assessment and seized…
2Cases cited18 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Geders v. United StatesSupreme Court of the United States · 1976
- Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
- Hannah v. LarcheSupreme Court of the United States · 1960
- Commissioner v. ShapiroSupreme Court of the United States · 1976
13 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Don Casey Co. v. CommissionerUnited States Tax Court · 1986
- Kovens v. CommissionerUnited States Tax Court · 1988
- Samuel Shapiro v. Commissioner of Internal Revenue, Samuel and Bella Shapiro v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
- Don Casey Co. v. CommissionerUnited States Tax Court · 1986
- Heltzer v. CommissionerUnited States Tax Court · 1991
2 more not listed; retrieve them via the Exa API.