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MORGAN v. U.S.

No. 90-16641.

958 F.2d 950 (1992)

Bruce MORGAN, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 11, 1992.

Attorney(s) appearing for the Case

Edward B. Simpson, Simpson & Gigounas, San Francisco, Cal., for plaintiff-appellant.

Kenneth L. Greene, Gary R. Allen, John A. Dudeck, Jr., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before FLETCHER, WIGGINS and KOZINSKI, Circuit Judges.

PER CURIAM:

Federal agents seized $191,900 in cash Morgan was carrying in his luggage when he landed at Oakland airport. He has never acknowledged ownership of the money. The IRS made a deficiency determination of $53,732 pursuant to section 6851(a), which provides for termination of the taxable year and immediate determination of the tax due, and section 6861(a), which authorizes immediate assessment of tax when collection will be jeopardized by delay.

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