Legal Opinion

Ryan v. Commissioner

United States Tax Court

Decided November 15, 1976No. Docket No. 4800-69Published

Petitioners were ordered by this Court to answer respondent's interrogatories but they refused to do so. Petitioners appealed from that order but the appeal was dismissed because our order was not a final order. Pending the appeal, petitioners were granted use immunity by an order of the U.S. District Court for the District of Columbia. Subsequently petitioners were again ordered by this Court to answer the interrogatories but they again refused to do so.

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Petitioners were ordered by this Court to answer respondent's interrogatories but they refused to do so. Petitioners appealed from that order but the appeal was dismissed because our order was not a final order. Pending the appeal, petitioners were granted use immunity by an order of the U.S. District Court for the District of Columbia. Subsequently petitioners were again ordered by this Court to answer the interrogatories but they again refused to do so. Held: Petitioners may not avoid answering the interrogatories on a claim of privilege under the fifth amendment to the U.S. Constitution.…

1Opinion of the Court

Raymond J. Ryan and Helen Ryan, Petitioners v. Commissioner of Internal Revenue, Respondent

Ryan v. Commissioner

Docket No. 4800-69

United States Tax Court

67 T.C. 212; 1976 U.S. Tax Ct. LEXIS 25;

November 15, 1976, Filed

Petitioners were ordered by this Court to answer respondent's interrogatories but they refused to do so. Petitioners appealed from that order but the appeal was dismissed because our order was not a final order. Pending the appeal, petitioners were granted use immunity by an order of the U.S. District Court for the District of Columbia. Subsequently petitioners were again ordered…

2Cases cited32 opinions

  1. United States v. United Mine Workers of AmericaSupreme Court of the United States · 1947
  2. Kastigar v. United StatesSupreme Court of the United States · 1972
  3. Hoffman v. United StatesSupreme Court of the United States · 1951
  4. Gompers v. Bucks Stove & Range Co.Supreme Court of the United States · 1911
  5. United States v. JanisSupreme Court of the United States · 1976

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