McWilliams v. Commissioner
United States Tax Court
R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. P requested an administrative review of the jeopardy assessment on the grounds that such assessment was unreasonable. R upheld the jeopardy assessment. P filed a motion for review of the jeopardy assessment and levy with this Court pursuant to sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure.
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R imposed a jeopardy assessment and levy on P under authority of sec. 6861, I.R.C. P requested an administrative review of the jeopardy assessment on the grounds that such assessment was unreasonable. R upheld the jeopardy assessment. P filed a motion for review of the jeopardy assessment and levy with this Court pursuant to sec. 7429(b)(2), I.R.C., and Rule 56, Tax Court Rules of Practice and Procedure. We are required to make a de novo determination within 20 days from the filing of a motion to review as to two issues: (1) Whether the making of the jeopardy assessment is reasonable under…
1Opinion of the Court
OPINION
Parr, Judge:
This matter is before the Court on petitioner’s motion for review of jeopardy assessment and levy filed August 11, 1994, pursuant to Rule 56.1 This case was tried in El Paso, Texas, in November 1993.2
In the notice of deficiency respondent determined the following deficiencies in and additions to petitioner’s Federal income taxes:
Additions to tax
Sec. Sec. Sec. Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6653(b)(1)(B) Sec. 6661(a)
1986 $58,761 $44,071 $14,690
1987 43,247 32,435 10,812
1988 156,393 $117,295 39,098
At trial, the parties made a number of concessions that dramatically…
2Cases cited10 opinions
- Loretto v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- McAvoy v. Internal Revenue ServiceDistrict Court, W.D. Michigan · 1979
- Fidelity Equipment Leasing Corp. v. United StatesDistrict Court, N.D. Georgia · 1978
- DeLauri v. United StatesDistrict Court, W.D. Texas · 1980
- Bremson v. United StatesDistrict Court, W.D. Missouri · 1978
5 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- McWilliams v. CommissionerUnited States Tax Court · 1995
- McWilliams v. CommissionerUnited States Tax Court · 1995
- Green v. Comm'rUnited States Tax Court · 2003
- Gaw v. CommissionerUnited States Tax Court · 1995
- George G. Green v. CommissionerUnited States Tax Court · 2003
3 more not listed; retrieve them via the Exa API.