Dimsdale v. Commissioner
United States Tax Court
Held, the affirmative allegations in R's answer were deemed admitted under Rule 37(c), Tax Court Rules of Practice and Procedure. Such allegations deemed admitted are sufficient to sustain deficiencies for the taxable years 1976 and 1977 against petitioner. Heldfurther, the allegations deemed admitted are sufficient to satisfy R's burden of proving fraud under sec. 6653(b) with respect to the taxable years 1976 and 1977. Doncaster v. Commissioner,77 T.C. 334 (1981), followed.
1Opinion of the Court
MORRIS JOE DIMSDALE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dimsdale v. Commissioner
Docket No. 7605-86.
United States Tax Court
T.C. Memo 1987-53; 1987 Tax Ct. Memo LEXIS 214; 52 T.C.M. (CCH) 1506; T.C.M. (RIA) 87053;
January 22, 1987.
Held, the affirmative allegations in R's answer were deemed admitted under Rule 37(c), Tax Court Rules of Practice and Procedure. Such allegations deemed admitted are sufficient to sustain deficiencies for the taxable years 1976 and 1977 against petitioner. Heldfurther, the allegations deemed admitted are sufficient to satisfy R's burden of…
2Cases cited7 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- Doncaster v. CommissionerUnited States Tax Court · 1981
- Stratton v. CommissionerUnited States Tax Court · 1970
- Marshall v. CommissionerUnited States Tax Court · 1985
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