Cochrane v. Commissioner
United States Tax Court
P was ordered to file responses to R's requests for admission. P's subsequent responses to the requests for admission were evasive and incomplete and contained time-worn tax protester statements. R moved for sanctions, asking that the matter in the requested admissions be taken as established for purposes of this case.
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P was ordered to file responses to R's requests for admission. P's subsequent responses to the requests for admission were evasive and incomplete and contained time-worn tax protester statements. R moved for sanctions, asking that the matter in the requested admissions be taken as established for purposes of this case. Rule 90(c), Tax Court Rules of Practice and Procedure, generally requires that a party upon whom a request for admission is served specifically admit or deny the proposed admission. Rule 104(c), Tax Court Rules of Practice and Procedure, provides that the Court may sanction a…
1Opinion of the Court
OPINION
Ruwe, Judge:
Respondent determined deficiencies in and additions to petitioner’s Federal income taxes as follows:
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The issues for decision are: (1) Whether petitioner received taxable income as determined by respondent for each of the years in issue; (2) whether petitioner is liable for an addition to tax for fraud under section 6653(b)1 for each of the years in issue; (3) whether petitioner is liable for an addition to tax for substantial understatement of income tax under section 6661 for 1984; and (4) whether petitioner is liable for an addition to tax for failure to pay…
2Cases cited23 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Beaver v. CommissionerUnited States Tax Court · 1970
- United States v. Ruth StudleyCourt of Appeals for the Ninth Circuit · 1986
18 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- JZ Buckingham Investments LLC v. United StatesUnited States Court of Federal Claims · 2007
- Lincir v. CommissionerUnited States Tax Court · 1999
- Cochrane v. CommissionerUnited States Tax Court · 1996
- James Luther Cochrane v. CommissionerUnited States Tax Court · 1996
- Quinn v. Comm'rUnited States Tax Court · 2012