Kamholz v. Commissioner
United States Tax Court
P presently has two petitions pending in this Court with respect to the year 1983, and a single petition pending with respect to the year 1984. R sent P a notice of intention to levy with respect to assessments made for the years 1983, 1985, and 1987. Held, this Court lacks jurisdiction under sec. 6213(a), I.R.C., to restrain R from collecting assessments pertaining to 1985 and 1987, because such years are not the subject of timely filed petitions pending in this Court.
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P presently has two petitions pending in this Court with respect to the year 1983, and a single petition pending with respect to the year 1984. R sent P a notice of intention to levy with respect to assessments made for the years 1983, 1985, and 1987. Held, this Court lacks jurisdiction under sec. 6213(a), I.R.C., to restrain R from collecting assessments pertaining to 1985 and 1987, because such years are not the subject of timely filed petitions pending in this Court. Held, further, since P's request for an injunction with respect to the year 1983 states grounds that are plausible and…
1Opinion of the Court
Gordon F. Kamholz, Petitioner v. Commissioner of Internal Revenue, Respondent
Kamholz v. Commissioner
Docket Nos. 34798-86, 27758-87
United States Tax Court
94 T.C. 11; 1990 U.S. Tax Ct. LEXIS 2; 94 T.C. No. 2;
January 11, 1990January 11, 1990, Filed
P presently has two petitions pending in this Court with respect to the year 1983, and a single petition pending with respect to the year 1984. R sent P a notice of intention to levy with respect to assessments made for the years 1983, 1985, and 1987. Held, this Court lacks jurisdiction under sec. 6213(a), I.R.C., to restrain R from collecting…
2Cases cited7 opinions
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- Laing v. United StatesSupreme Court of the United States · 1976
- Bruce Perlowin v. Michael D. Sassi, District Director of Internal Revenue, San Francisco, California, and United States of AmericaCourt of Appeals for the Ninth Circuit · 1983
- Kamholz v. CommissionerUnited States Tax Court · 1990
- Williams v. CommissionerUnited States Tax Court · 1989
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