Legal Opinion

Estate of Van Loben Sels v. Commissioner

United States Tax Court

Decided January 9, 1984No. Docket No. 30439-81PublishedCited by 4 opinions

Petitioner moved for a continuance under Rule 134, Tax Court Rules of Practice and Procedure, and for an order compelling attendance at deposition pursuant to subpoena duces tecum under Rule 75, Tax Court Rules of Practice and Procedure. The main case involves respondent's determination of a deficiency in petitioner's estate tax, the central issue therein being the value of various undivided minority interests in certain timberlands as of the date of decedent's death.

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Petitioner moved for a continuance under Rule 134, Tax Court Rules of Practice and Procedure, and for an order compelling attendance at deposition pursuant to subpoena duces tecum under Rule 75, Tax Court Rules of Practice and Procedure. The main case involves respondent's determination of a deficiency in petitioner's estate tax, the central issue therein being the value of various undivided minority interests in certain timberlands as of the date of decedent's death. Petitioner asserted its need for a continuance in order to obtain and evaluate information as to the valuation issue.…

1Opinion of the Court

OPINION

Hamblen, Judge:

This matter is before the Court on petitioner’s motion for continuance under Rule 1341 filed on November 9, 1983, and petitioner’s motion for order compelling attendance at deposition pursuant to subpoena duces tecum under Rule 75(d) filed on November 25, 1983. Respondent opposes each of said motions.

Pursuant to notice, a hearing on both motions was held on November 30, 1983, in Washington, D.C. Counsel for both parties appeared at the hearing and presented argument. In addition, various memoranda have been filed by each party setting forth their respective positions as…

2Cases cited1 opinion

  1. Stern v. CommissionerUnited States Tax Court · 1980

3Cited by4 opinions

  1. De Lucia v. CommissionerUnited States Tax Court · 1986
  2. De Lucia v. CommissionerUnited States Tax Court · 1986
  3. Estate of Van Loben Sels v. CommissionerUnited States Tax Court · 1984
  4. Howe v. CommissionerUnited States Tax Court · 1985

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