James R. Davis v. Commissioner of Internal Revenue

ORDER

This appeal has been referred to a panel of the Court pursuant to Rule 9(a), Rules of the Sixth Circuit. After examination of the briefs and record, this panel agrees unanimously that oral argument is not needed. Rule 34(a), Federal Rules of Appellate Procedure.

Petitioner received a notice of deficiency for his income tax for 1976. Disagreeing with the determinations, petitioner filed a petition in the Tax Court for a redetermination. The Commissioner filed an answer which petitioner thought was too general, so he moved to hold the Commissioner in default. The court denied the motion and…