International Air Conditioning Corp. v. Commissioner
United States Tax Court
Rule 70(a)(1), Tax Court Rules of Practice and Procedure. -- As a prerequisite to partaking in any informal discussion, petitioners' counsel required respondent to answer detailed questions regarding facts, legal theories, case law, and other authorities on which respondent relied in computing petitioners' deficiencies.
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Rule 70(a)(1), Tax Court Rules of Practice and Procedure. -- As a prerequisite to partaking in any informal discussion, petitioners' counsel required respondent to answer detailed questions regarding facts, legal theories, case law, and other authorities on which respondent relied in computing petitioners' deficiencies. Held: Petitioners' counsel has not made a good faith effort to comply with the directive of Rule 70(a)(1) that urges the parties to undertake informal consultation or communication before utilizing formal discovery procedures. Therefore, petitioners' Interrogatories Motions…
1Opinion of the Court
OPINION
Wiles, Judge:
On March 17, 1976, each petitioner filed a "Motion for Order Compelling the Respondent to Serve Adequate and Complete Answers to Petitioner’s Interrogatories or to Render a Judgment by Default Against the Respondent” (Interrogatories Motions). On March 26, 1976, each petitioner filed a "Motion for Order to have the Petitioner’s Request for Admissions Deemed Admitted” (Admissions Motions). Oral arguments on these motions were heard May 10, 1976, at Lubbock, Tex.
The events leading to the argument of these motions are as follows: On March 18, 1975, respondent issued…
2Cases cited1 opinion
- Branerton Corp. v. CommissionerUnited States Tax Court · 1974
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