Stern v. Commissioner
United States Tax Court
Respondent has subpoenaed certain records from Bank of America N.T. & S.A. (Bank). The records related to a trust to which petitioners had transferred contingent shares received under a corporate acquisition, a transfer not disclosed on petitioners' return. The contents of the trust and the transfer had first become known to respondent only after respondent had obtained certain subpoenaed documents from petitioners.
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Respondent has subpoenaed certain records from Bank of America N.T. & S.A. (Bank). The records related to a trust to which petitioners had transferred contingent shares received under a corporate acquisition, a transfer not disclosed on petitioners' return. The contents of the trust and the transfer had first become known to respondent only after respondent had obtained certain subpoenaed documents from petitioners. Held, under the circumstances, Bank's motion to be reimbursed for costs of compliance with the subpoena is denied.
1Opinion of the Court
OPINION
Hall, Judge:
On April 29, 1980, the Bank of America N.T. & S.A. (the bank) filed a motion for protective order pursuant to Rule 147(b), Tax Court Rules of Practice and Procedure, requesting the Court to order respondent to compensate the bank for all reasonable costs incurred in connection with the production of additional documents in this case. A brief summary of the prior procedural motions involved in this case is necessary in order to place the bank’s request in its proper perspective.
On September 26, 1978, respondent issued a statutory notice of deficiency wherein he asserted…
2Cases cited10 opinions
- Securities and Exchange Commission v. Arthur Young & CompanyCourt of Appeals for the D.C. Circuit · 1978
- United States v. FriedmanCourt of Appeals for the Third Circuit · 1976
- United States v. American Optical Co.District Court, N.D. California · 1966
- Securities & Exchange Commission v. OKC Corp.District Court, N.D. Texas · 1979
- Celanese Corporation & Fiber Industries, Inc. v. E. I. Dupont De Nemours & Co.District Court, D. Delaware · 1973
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3Cited by9 opinions
- Stern v. CommissionerUnited States Tax Court · 1981
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