Legal Opinion
Samuel Shapiro v. Commissioner of Internal Revenue, Samuel and Bella Shapiro v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 30, 1980No. 80-4055, 80-8017PublishedCited by 7 opinions
1Opinion of the Court
ORDER
In our view taxpayers’ motion for leave to appeal under 28 U.S.C. § 1292(b) should be denied and the Commissioner’s motion to dismiss the appeal should be granted.
If this were an appeal from the interlocutory order of a district court as opposed to the Tax Court, 73 T.C. 313, we might well accept a certification, because the question whether an IRS jeopardy assessment can be used to freeze assets of a taxpayer needed to pay attorneys’ fees and to prepare his case fully is a question that has never been resolved by this court and appears to raise an important legal question. The Tax Court…
2Cases cited5 opinions
- Cohen v. Beneficial Industrial Loan Corp.Supreme Court of the United States · 1949
- Coopers & Lybrand v. LivesaySupreme Court of the United States · 1978
- Commissioner of Internal Revenue v. Smith Paper, Inc.Court of Appeals for the First Circuit · 1955
- Stanley M. Rosenblum v. United StatesCourt of Appeals for the Eighth Circuit · 1977
- Shapiro v. CommissionerUnited States Tax Court · 1979
3Cited by7 opinions
- General Signal Corp. v. CommissionerUnited States Tax Court · 1995
- Kovens v. CommissionerUnited States Tax Court · 1988
- De Lucia v. CommissionerUnited States Tax Court · 1986
- De Lucia v. CommissionerUnited States Tax Court · 1986
- Gary M. Weichlein and Trudy J. Weichlein v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
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