Legal Opinion

Armco, Inc. v. Commissioner

United States Tax Court

Decided October 28, 1986No. Docket Nos. 20037-85, 45229-85Published

P sought a pretrial ruling on the admissibility of an affidavit of a former Treasury Department and Internal Revenue Service employee, now deceased, who assisted in drafting sec. 1.167(a)-11(d)(2), Income Tax Regs., to explain the intended meaning of the regulation. The affidavit was prepared in 1983, 12 years after the regulation was adopted.

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P sought a pretrial ruling on the admissibility of an affidavit of a former Treasury Department and Internal Revenue Service employee, now deceased, who assisted in drafting sec. 1.167(a)-11(d)(2), Income Tax Regs., to explain the intended meaning of the regulation. The affidavit was prepared in 1983, 12 years after the regulation was adopted. Held: The affidavit is irrelevant and therefore inadmissible under rule 401, Federal Rules of Evidence, because the affidavit expresses only an individual opinion and is not a statement of institutional intent, and was not contemporaneous with the…

1Opinion of the Court

Armco, Inc. Formerly Armco Steel Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent; Armco, Inc. and Subsidiaries, Formerly Armco Steel Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Armco, Inc. v. Commissioner

Docket Nos. 20037-85, 45229-85

United States Tax Court

87 T.C. 865; 1986 U.S. Tax Ct. LEXIS 30; 87 T.C. No. 55;

October 28, 1986, Filed

P sought a pretrial ruling on the admissibility of an affidavit of a former Treasury Department and Internal Revenue Service employee, now deceased, who assisted in drafting sec.…

2Cases cited6 opinions

  1. Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
  2. Jewett v. CommissionerSupreme Court of the United States · 1982
  3. Estate of Lang v. CommissionerUnited States Tax Court · 1975
  4. The Estate of Grace E. Lang, Deceased. Richard E. Lang v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  5. Armco, Inc. v. CommissionerUnited States Tax Court · 1986

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