Pearsall v. Commissioner
United States Tax Court
Rule 90, Tax Court Rules of Practice and Procedure. -- Petitioners filed a request for admissions. Without admitting, denying, or qualifying any request the respondent moved for a protective order under Rule 103(a)(1) and (2). Held: The proper procedure in this case is for respondent to respond to the request for admissions pursuant to Rule 90(c). Motion for protective order will be denied.
1Opinion of the Court
OPINION
Dawson, Judge:
In reply to a request for admissions filed by the petitioners, respondent has moved for a protective order pursuant to Rule 103(a) (1) and (2), Tax Court Rules of Practice and Procedure. The relief sought is that the respondent need not respond to the request for admissions or, in the alternative, that he need not respond at this time.
Petitioners filed their petition in this proceeding on May 16, 1973, seeking a redetermination of Federal income tax deficiencies for the years 1969,1970, and 1971. Respondent’s answer was filed on June 26, 1973. Petitioners then filed a…
2Cases cited8 opinions
- Shiosaki v. CommissionerUnited States Tax Court · 1974
- Branerton Corp. v. CommissionerUnited States Tax Court · 1974
- Florence O'CampO v. Edna Hardisty, Paul H. Wright, R. v. Rushford, N. P. Hughes and N. DrakulichCourt of Appeals for the Ninth Circuit · 1958
- Syracuse Broadcasting Corporation v. Samuel I. Newhouse, the Herald Company, the Post-Standard Company and Central New York Broadcasting CorporationCourt of Appeals for the Second Circuit · 1959
- Moosman v. Joseph P. Blitz, Inc.Court of Appeals for the Second Circuit · 1966
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Odend'hal v. CommissionerUnited States Tax Court · 1980
- Estate of Allensworth v. CommissionerUnited States Tax Court · 1976
- Boso v. CommissionerUnited States Tax Court · 1995
- Estate of Allensworth v. CommissionerUnited States Tax Court · 1976
4 more not listed; retrieve them via the Exa API.