Legal Opinion

Powerstein v. Commissioner

United States Tax Court

Decided September 30, 1992No. Docket No. 30261-89Published

R made a jeopardy assessment of deficiencies in Ps' Federal income tax for the taxable years 1984 through 1988 followed by the issuance of a notice of deficiency determining the same deficiencies. Ps filed a timely petition contesting R's determination.

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R made a jeopardy assessment of deficiencies in Ps' Federal income tax for the taxable years 1984 through 1988 followed by the issuance of a notice of deficiency determining the same deficiencies. Ps filed a timely petition contesting R's determination. R's answer contains allegations that the deficiency notice overstates Ps' reconstructed income for the taxable years 1984 and 1985 and understates Ps' reconstructed income for the taxable years 1986, 1987, and 1988. R's answer includes a claim for increased deficiencies for the taxable years 1986 through 1988. Subsequent to the filing of R's…

1Opinion of the Court

Allen Powerstein and Rita Powerstein Rosen, Petitioners v. Commissioner of Internal Revenue, Respondent

Powerstein v. Commissioner

Docket No. 30261-89

United States Tax Court

99 T.C. 466; 1992 U.S. Tax Ct. LEXIS 74; 99 T.C. No. 22;

September 30, 1992, Filed

An appropriate order will be entered.

R made a jeopardy assessment of deficiencies in Ps' Federal income tax for the taxable years 1984 through 1988 followed by the issuance of a notice of deficiency determining the same deficiencies. Ps filed a timely petition contesting R's determination. R's answer contains allegations that the deficiency…

2Cases cited11 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Jasionowski v. CommissionerUnited States Tax Court · 1976
  3. Robert F. Koch and Evelyn C. Koch v. Donald C. Alexander, Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1977
  4. Meyer v. CommissionerUnited States Tax Court · 1991
  5. Powell v. CommissionerUnited States Tax Court · 1991

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