KEITH v. COMMISSIONER

Docket No. 35296-85.

57 T.C.M. 1351 (1989)

T.C. Memo. 1989-437

Charles R. Keith, as possessor of certain cash v. Commissioner.

United States Tax Court.

Filed August 17, 1989.


Attorney(s) appearing for the Case

Evelyn E. Small, 1111 E. Main St., Richmond, Va., for the petitioner. John C. McDougal, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined that petitioner, as possessor of certain cash, owed a deficiency in Federal income tax of $16,000 for 1984. The issues for decision are: 1) whether we have jurisdiction to determine the true owner of cash seized pursuant to sections 68511 and 6867; 2) whether we have jurisdiction to consider the validity of a deficiency notice in the section 6867 context...

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