Legal Opinion
Estate of Quirk v. Commissioner
United States Tax Court
Decided June 28, 1973No. Docket No. 8428-72PublishedCited by 16 opinions
Respondent's untimely motion for leave to file answer out of time is denied.
1Opinion of the Court
OPINION AND ORDER
Forrester, Judge:
Respondent has moved for leave to file his answer out of time. The motion itself was untimely and petitioner opposes it, relying in part on an unreported Memorandum Sur Order filed by this Court on July 18, 1972, in Clark Tank Lines Company, Inc., docket No. 721-71.
In a notice of deficiency dated November 1, 1972, and addressed to petitioner in Los Angeles, Calif., respondent determined an estate tax deficiency of $135,210.49, and an addition to tax under section 6653 (b) (fraud), I.R.C. 1954, of $67,605.24. Petitioner filed a timely petition with this Court…
2Cases cited4 opinions
- Morris Newmark and Julia Newmark v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Board of Tax Appeals v. United States ex rel. Shults Bread Co.Court of Appeals for the D.C. Circuit · 1929
- Moran v. CommissionerUnited States Tax Court · 1966
- Shults Bread Co. v. CommissionerUnited States Board of Tax Appeals · 1928
3Cited by16 opinions
- Vermouth v. CommissionerUnited States Tax Court · 1987
- Betz v. CommissionerUnited States Tax Court · 1988
- Dixon v. CommissionerUnited States Tax Court · 1973
- Ballantine v. CommissionerUnited States Tax Court · 1980
- Rea v. CommissionerUnited States Tax Court · 1973
11 more not listed; retrieve them via the Exa API.