Legal Opinion

Snyder v. Commissioner

United States Tax Court

Decided November 2, 1989No. Docket Nos. 28964-87, 28965-87, 3471-88, 3472-88PublishedCited by 41 opinions

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

  1. Anderson v. United StatesSupreme Court of the United States · 1974
  2. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  3. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
  4. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  5. Chiu v. CommissionerUnited States Tax Court · 1985

17 more not listed; retrieve them via the Exa API.

3Cited by41 opinions

  1. Wendt v. WendtConnecticut Appellate Court · 2000
  2. Custom Chrome, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
  3. Conti v. CommissionerUnited States Tax Court · 1992
  4. Nationalist Movement v. CommissionerUnited States Tax Court · 1994
  5. Jameson v. CommissionerUnited States Tax Court · 1999

36 more not listed; retrieve them via the Exa API.

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