Shaheen v. Commissioner
United States Tax Court
Rule 120, Tax Court Rules of Practice and Procedure. -- Respondent filed a motion for judgment on the pleadings on the ground that a prior default judgment declaring Federal income taxes and additions to the taxes to be due from the petitioner for the years 1966, 1967, and 1968 -- the same taxes and years presently before this Court -- was entered by the United States District Court for the Northern District of Illinois and was not appealed.
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Rule 120, Tax Court Rules of Practice and Procedure. -- Respondent filed a motion for judgment on the pleadings on the ground that a prior default judgment declaring Federal income taxes and additions to the taxes to be due from the petitioner for the years 1966, 1967, and 1968 -- the same taxes and years presently before this Court -- was entered by the United States District Court for the Northern District of Illinois and was not appealed. Held, (1) the judgment of the United States District Court is res judicata of petitioner's tax liabilities for the taxable years in question; and (2)…
1Opinion of the Court
OPINION
Dawson, Judge:
On January 2, 1974, pursuant to Rule 120, Tax Court Rules of Practice and Procedure, the respondent filed a motion for judgment on the pleadings in this case on the ground that the United States District Court for the Northern District of Illinois had entered a judgment that was res judicata of the deficiencies in Federal income taxes and additions to the taxes due from the petitioner for the taxable years at issue in this proceeding. A hearing on the motion was held on February 27, 1974. Memorandum briefs have been submitted by both parties. The chronology of pertinent…
2Cases cited21 opinions
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