GALUSHA v. COMMISSIONER

Docket No. 17256-90.

95 T.C. 218 (1990)

GERALD A. GALUSHA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 4, 1990.


Attorney(s) appearing for the Case

F. Michael Kovach, for the petitioner.

Milton J. Carter, Jr., for the respondent.


OPINION

GERBER, Judge:

Petitioner seeks to stay the sale of a boat under section 6863(b)(3).1 Respondent, under section 6861, made a jeopardy assessment on June 1, 1990, for an amount in excess of $223,000. Petitioner purchased, on March 20, 1990, for $72,500, a boat which respondent seized pursuant to the jeopardy assessment. Respondent advertised the boat to be sold on August 1, 1990. On July 27, 1990, respondent mailed...

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