Corelli v. Commissioner
United States Tax Court
Rules 72 and 90, Tax Court Rules of Practice and Procedure. -- A private ruling letter issued by the Internal Revenue Service to an applicant other than petitioner covers contractual arrangements among petitioner and others relating to compensation which petitioner did not report as income. In the statutory notice such compensation is charged to petitioner and the negligence penalty is asserted against him.
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Rules 72 and 90, Tax Court Rules of Practice and Procedure. -- A private ruling letter issued by the Internal Revenue Service to an applicant other than petitioner covers contractual arrangements among petitioner and others relating to compensation which petitioner did not report as income. In the statutory notice such compensation is charged to petitioner and the negligence penalty is asserted against him. Held, the private ruling letter and related papers are not privileged and are relevant to the subject matter in this proceeding and are, therefore, discoverable under Rules 72(b) and 90.
1Opinion of the Court
Franco Corelli, Petitioner v. Commissioner of Internal Revenue, Respondent
Corelli v. Commissioner
Docket Nos. 302-74, 1848-74
United States Tax Court
66 T.C. 220; 1976 U.S. Tax Ct. LEXIS 116;
May 4, 1976, Filed
Rules 72 and 90, Tax Court Rules of Practice and Procedure. -- A private ruling letter issued by the Internal Revenue Service to an applicant other than petitioner covers contractual arrangements among petitioner and others relating to compensation which petitioner did not report as income. In the statutory notice such compensation is charged to petitioner and the negligence penalty is…
2Cases cited7 opinions
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Davis v. CommissionerUnited States Tax Court · 1976
- Douglas J. And Marguerite H. Lemery, and Raymond J. And Myrtle Lemery v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Teichgraeber v. CommissionerUnited States Tax Court · 1975
- Lemery v. CommissionerUnited States Tax Court · 1970
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