Armco, Inc. v. Commissioner
United States Tax Court
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.
Read the full summary
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
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Jewett v. CommissionerSupreme Court of the United States · 1982
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- The Estate of Grace E. Lang, Deceased. Richard E. Lang v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Armco, Inc. v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.