Legal Opinion

Levine v. Commissioner

United States Tax Court

Decided November 10, 1987No. Docket No. 40372-86UnpublishedCited by 1 opinion

A petition was filed with this Court subsequent to the appointment of a receiver in an action commenced by the Securities and Exchange Commission against P (husband) in the United States District Court. Some, but not all, of P's (husband) assets were turned over to the receiver.

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A petition was filed with this Court subsequent to the appointment of a receiver in an action commenced by the Securities and Exchange Commission against P (husband) in the United States District Court. Some, but not all, of P's (husband) assets were turned over to the receiver. Held, section 6871(c) provides that no petition for redetermination shall be filed in the Tax Court after appointment of a receiver and, accordingly, we have no jurisdiction with respect to P (husband). Held further, R's Motion to Dismiss for Lack of Jurisdiction as to P (husband) is granted.

1Opinion of the Court

DENNIS B. LEVINE AND LAURIE LEVINE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Levine v. Commissioner

Docket No. 40372-86.

United States Tax Court

T.C. Memo 1987-564; 1987 Tax Ct. Memo LEXIS 562; 54 T.C.M. (CCH) 1064; T.C.M. (RIA) 87564;

November 10, 1987.

A petition was filed with this Court subsequent to the appointment of a receiver in an action commenced by the Securities and Exchange Commission against P (husband) in the United States District Court. Some, but not all, of P's (husband) assets were turned over to the receiver. Held, section 6871(c) provides that no petition for…

2Cases cited7 opinions

  1. Securities and Exchange Commission v. Manor Nursing Centers, Inc.Court of Appeals for the Second Circuit · 1972
  2. Baron v. CommissionerUnited States Tax Court · 1979
  3. Jamy Corporation, a California Corporation v. Robert A. Riddell, Individually and as District Director of Internal Revenue, Los Angeles, CaliforniaCourt of Appeals for the Ninth Circuit · 1964
  4. Ross v. CommissionerUnited States Tax Court · 1962
  5. Williams v. CommissionerUnited States Tax Court · 1965

2 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Appleton v. Comm'rUnited States Tax Court · 2010

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