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amount of tax shown on the taxpayer's return. Meyer v.
Commissioner, supra at 559-560, and cases cited therein. Such
summary assessments are not subject to the normal deficiency
procedures. Id. at 560.
Section 6213(a) was amended, effective with respect to
orders entered after November 10, 1988, to extend to this Court
jurisdiction to restrain assessment and collection of a
deficiency in cases where "a timely petition for a
redetermination of the deficiency has been filed and then only in
respect of the deficiency that is the subject of such petition."
Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647,
sec. 6243(a), 102 Stat. 3749; Kamholz v. Commissioner, 94 T.C.
11, 15 (1990). Consistent with the Court's statutorily
prescribed jurisdiction in this area, resolution of petitioners'
Motion to Restrain Collection depends upon whether respondent has
assessed and is attempting to collect the deficiency that is the
proper subject of petitioners' timely filed petition for
redetermination. Powerstein v. Commissioner, 99 T.C. at 471-472,
and cases cited therein.
In the instant case, it is clear that the amount that
respondent has assessed, and is attempting to collect, consists
of the tax that petitioners reported due on their original income
tax return for 1990, as well as statutory interest and penalties
imposed as a consequence of petitioners' failure to remit payment
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