Legal Opinion

Freedson v. Commissioner

United States Tax Court

Decided November 12, 1975No. Docket Nos. 6020-72, 6348-72PublishedCited by 135 opinions

On July 25, 1975, respondent served on petitioners' counsel in each of these two cases and, in due course, filed with this Court a Request for Admissions in accordance with Rule 90, Tax Court Rules of Practice and Procedure. Petitioners have filed no response to these requests. Respondent has filed in each case a Motion for Entry of Order that Respondent's Request for Admissions be Deemed Admitted.

Read the full summary

On July 25, 1975, respondent served on petitioners' counsel in each of these two cases and, in due course, filed with this Court a Request for Admissions in accordance with Rule 90, Tax Court Rules of Practice and Procedure. Petitioners have filed no response to these requests. Respondent has filed in each case a Motion for Entry of Order that Respondent's Request for Admissions be Deemed Admitted. Held: Under Rule 90(c) of the Rules of Practice and Procedure of this Court, if no response is made to a request for admissions which has been properly served, the statements of fact in the request…

1Opinion of the Court

OPINION

Featherston, Judge:

On July 29, 1975, the Court received the original of respondent’s Request for Admissions in each of these cases. One request contained 13 numbered paragraphs and the other 5. Each paper bears a Certificate of Service which recites that a copy thereof was served on petitioners’ counsel, Melvin M. Engel, on July 25, 1975, by certified mail, return receipt requested, in a postage-paid wrapper addressed to counsel at his address shown on the petitions. No response to these requests for admissions has been filed with the Court.

On September 12, 1975, respondent filed in…

2Cases cited4 opinions

  1. Florence O'CampO v. Edna Hardisty, Paul H. Wright, R. v. Rushford, N. P. Hughes and N. DrakulichCourt of Appeals for the Ninth Circuit · 1958
  2. Moosman v. Joseph P. Blitz, Inc.Court of Appeals for the Second Circuit · 1966
  3. Eugene Mangan v. Broderick and Bascom Rope CompanyCourt of Appeals for the Seventh Circuit · 1965
  4. Water Hammer Arrester Corp. v. TowerCourt of Appeals for the Seventh Circuit · 1949

3Cited by135 opinions

  1. Dahlstrom v. CommissionerUnited States Tax Court · 1985
  2. Marshall v. CommissionerUnited States Tax Court · 1985
  3. Morrison v. CommissionerUnited States Tax Court · 1983
  4. Freedson v. CommissionerUnited States Tax Court · 1977
  5. Estate of Cardulla v. CommissionerUnited States Tax Court · 1986

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API