Wagner v. Commissioner of Internal Revenue

118 T.C. 330 (2002)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

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.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 743,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 743,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 743,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership