Wagner v. Commissioner of Internal Revenue

118 T.C. 330 (2002)

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Wagner v. Commissioner of Internal Revenue

United States Tax Court
118 T.C. 330 (2002)

Facts

The Internal Revenue Service (IRS) (defendant) issued a notice of a tax lien on the assets of Richard and Margie Wagner (plaintiffs) as part of an effort to collect the Wagners’ 1991 tax liability. The Wagners filed a petition under § 6320(c) of the Internal Revenue Code (code) with the United States Tax Court to review the lien. After the IRS responded to the Wagners’ petition, the Wagners sought to file a lawsuit in federal district court for a ruling that they had incurred a net operating loss that could be used to offset their 1991 tax liability. The Wagners’ petition served to grant exclusive jurisdiction to the Tax Court over matters concerning the Wagners’ 1991 tax liability, preventing the Wagners from pursuing their lawsuit in district court. To remedy this, the Wagners filed a motion with the Tax Court to dismiss their petition without prejudice.

Rule of Law

Issue

Holding and Reasoning (Laro, J.)

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