Legal Opinion

Estate of Allensworth v. Commissioner

United States Tax Court

Decided April 6, 1976No. Docket No. 6073-75Published

Rule 90(a) and (d), Tax Court Rules of Practice and Procedure. -- Under Rule 90, the petitioner duly served on the Commissioner requests that he admit certain matters, including statements of the positions to be adopted by him concerning the construction of a will, statements of his views as to the application of the law to the facts of the case, and statements of the contentions to be maintained by him in the case.

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Rule 90(a) and (d), Tax Court Rules of Practice and Procedure. -- Under Rule 90, the petitioner duly served on the Commissioner requests that he admit certain matters, including statements of the positions to be adopted by him concerning the construction of a will, statements of his views as to the application of the law to the facts of the case, and statements of the contentions to be maintained by him in the case. Held, such matters may properly be the subject of requests for admissions under Rule 90, and the Commissioner will be ordered to furnish proper answers to such requests.

1Opinion of the Court

Estate of William R. Allensworth, Deceased, David Allensworth and First Galesburg National Bank & Trust Company, Co-Executors, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Allensworth v. Commissioner

Docket No. 6073-75

United States Tax Court

66 T.C. 33; 1976 U.S. Tax Ct. LEXIS 134;

April 6, 1976, Filed

Rule 90(a) and (d), Tax Court Rules of Practice and Procedure. -- Under Rule 90, the petitioner duly served on the Commissioner requests that he admit certain matters, including statements of the positions to be adopted by him concerning the construction of a will,…

2Cases cited6 opinions

  1. Stone v. CommissionerUnited States Tax Court · 1954
  2. Estate of Allensworth v. CommissionerUnited States Tax Court · 1976
  3. Pearsall v. CommissionerUnited States Tax Court · 1974
  4. Ryskiewicz v. CommissionerUnited States Tax Court · 1974
  5. Barkett v. CommissionerUnited States Tax Court · 1959

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