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MIRAVALLE v. COMMISSIONER

Docket Nos. 9870-91, 7251-93, 10686-94.

105 T.C. 65 (1995)

DONALD J. MIRAVALLE AND LILLIAN JOY MIRAVALLE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 1995.

Attorney(s) appearing for the Case

Donald J. Miravalle and Lillian Joy Miravalle, pro se.

Howard P. Levine, for respondent.

OPINION

GERBER, Judge:

Petitioners moved to stay respondent's sale of property. We consider whether the provisions of section 68631 would grant us jurisdiction to stay the sale.

Background

Respondent made jeopardy assessments of and issued a notice of deficiency for deficiencies in petitioners' income tax for 1984, 1985, and 1986 tax years. Shortly after making the jeopardy assessments in December...

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