McWilliams v. Commissioner
United States Tax Court
R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. Pursuant to P's motion made in accordance with sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure, this Court held for petitioner and ordered abatement of the jeopardy assessment and release of the levy.
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R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. Pursuant to P's motion made in accordance with sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure, this Court held for petitioner and ordered abatement of the jeopardy assessment and release of the levy. McWilliams v. Commissioner, 103 T.C. 416 (1994). P filed a motion for attorney's fees and administrative costs pursuant to sec. 7430, I.R.C., and Rule 231, Tax Court Rules of Practice and Procedure. The underlying deficiency proceeding has not yet been decided. Held, disposition of…
1Opinion of the Court
OPINION
Parr, Judge:
This matter is before the Court on petitioner’s motion for litigation and administrative costs filed September 30, 1994, pursuant to Rule 2311 and section 7430. Respondent determined deficiencies in and additions to petitioner’s Federal income taxes for tax years 1986, 1987, and 1988. The case has been docketed, tried, and submitted to the Court for decision but has not yet been decided. After trial, respondent made a jeopardy assessment against petitioner and a jeopardy levy on petitioner’s property. On July 21, 1994, petitioner and his wife2 requested an administrative…
2Cases cited14 opinions
- Estate of William Davidson Merchant, Iii, Deceased, Margaret Norling Merchant, Administrator v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
- Loretto v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- Haskin v. United StatesDistrict Court, C.D. California · 1977
- Bobbie J. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Groetzinger v. CommissionerUnited States Tax Court · 1986
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3Cited by7 opinions
- Corkrey v. CommissionerUnited States Tax Court · 2000
- Nu-Look Design, Inc. v. Comm'rUnited States Tax Court · 2003
- Dixon v. Comm'rUnited States Tax Court · 2006
- Corkrey v. CommissionerUnited States Tax Court · 2000
- McWilliams v. CommissionerUnited States Tax Court · 1995
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