Snyder v. Commissioner
United States Tax Court
P seeks to strike from R's reply brief references to and quotations from technical books and articles not proffered at trial, relied on, or referred to by any expert witness. Held, this material is hearsay not subject to the exception for learned treaties pursuant to Rule 803(18), Fed. R. Evid.Held, further, this material is not suitable for the Court to take judicial notice of pursuant to Rule 201, Fed.
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P seeks to strike from R's reply brief references to and quotations from technical books and articles not proffered at trial, relied on, or referred to by any expert witness. Held, this material is hearsay not subject to the exception for learned treaties pursuant to Rule 803(18), Fed. R. Evid.Held, further, this material is not suitable for the Court to take judicial notice of pursuant to Rule 201, Fed. R. Evid.Held, further: Rule 143(b), Tax Court Rules of Practice and Procedure, precludes our consideration of this "Brandeis brief" material. P transferred to L 300 shares of publicly traded…
1Opinion of the Court
WILLIAMS, Judge:
The Commissioner determined deficiencies in petitioners’ respective gift taxes in the following amounts for the following periods:
Petitioner Elizabeth W. Snyder Docket Nos. 28964-87, 3471-88
Period Deficiency
4/1/81-6/30/81. $474,643
7/1/81-9/30/81 . 66,739
10/1/81-12/31/81. 59,160
1982. 96,902
1983. 70,520
1984. 77,954
1985 . 62,047
Petitioner Ritchie A. Snyder Docket Nos. 28965-87, 3472-88
Period Deficiency
4/1/81-6/30/81 $463,122
1982. 91,762
1983. 63,415
1984. 74,361
1985. 55,568
The issues we must decide are: (1) The fair market value of common stock that petitioner Elizabeth W. Snyder…
2Cases cited22 opinions
- Anderson v. United StatesSupreme Court of the United States · 1974
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Chiu v. CommissionerUnited States Tax Court · 1985
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3Cited by41 opinions
- Wendt v. WendtConnecticut Appellate Court · 2000
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- Conti v. CommissionerUnited States Tax Court · 1992
- Nationalist Movement v. CommissionerUnited States Tax Court · 1994
- Jameson v. CommissionerUnited States Tax Court · 1999
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