§6247

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

Section 7421, commonly called the Anti-Injunction Act, provides that "no suit for the purpose ofrestraining the assessment or collection ofany tax shall be maintained in any court by any person." The section 6707 penalty is an "assess- able penalty." Because the pending IRS administrative proceeding involves a pro- posed "assessment * * * of[a] tax," section 7421(a)

been filed and then only in respect ofthe adjustments that are the subject ofsuch petition." Section 6246(b) similarly authorizes the Court to enjoin a premature "adjustment to any partnership item" but only if"a timely petition has been filed under section 6247 and then only in respect ofthe adjustments that are the subject ofsuch petition." 5Petitioners' argument that their motion "does not target either assessment or collection" and "does not seek to stop respondent from taking action" is non

been filed and then only in respect ofthe adjustments that are the subject ofsuch petition." Section 6246(b) similarly authorizes the Court to enjoin a premature "adjustment to any partnership item" but only if"a timely petition has been filed under section 6247 and then only in respect ofthe adjustments that are the subject ofsuch petition." 5Petitioners' argument that their motion "does not target either assessment or collection" and "does not seek to stop respondent from taking action" is non

been filed and then only in respect ofthe adjustments that are the subject ofsuch petition." Section 6246(b) similarly authorizes the Court to enjoin a premature "adjustment to any partnership item" but only if"a timely petition has been filed under section 6247 and then only in respect ofthe adjustments that are the subject ofsuch petition." 5Petitioners' argument that their motion "does not target either assessment or collection" and "does not seek to stop respondent from taking action" is non

Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6246, 102 Stat. 3751 (jurisdiction to review interest assessed on deficiency determined by the Tax Court effective with assessments made after date of enactment); TAMRA, sec. 6247, 102 Stat. 3751 (jurisdiction to reopen estate tax cases to determine deduction for interest paid on installments of taxes effective for cases for which the decision is not final on date of enactment). - 8 - SEC. 6215. ASSESSMENT OF DEFICIE

il the final installment of the estate tax liability is due, or paid, whichever is earlier. Section 7481(d) was enacted in 1988 in response to Estate of Bailly v. Commissioner, supra. Technical and Miscellaneous Revenue Act of 1988, Pub. L. 102-647, sec. 6247, 100 Stat. 3342, 3751-3752. Under section 7481(d), a taxpayer may move to reopen a case to which an extension of time to pay estate tax under section 6166 applies to ask the Court to modify the amount of the estate's deduction for interest.