Legal Opinion

Hajecate v. Commissioner

United States Tax Court

Decided February 17, 1988No. Docket Nos. 498-81, 499-81, 500-81, 1250-82, 1251-82, 792-83, 793-83, 794-83, 795-83, 6809-83, 626-85PublishedCited by 10 opinions

Ps were targeted for grand jury investigation in the late 1970s. In 1979 and 1981, R obtained orders from a U.S. District Court pursuant to rule 6(e) of the Federal Rules of Criminal Procedure (rule 6(e)) permitting him to examine transcripts of testimony and materials relating to Ps' business operations obtained from several grand juries to determine whether any civil tax liabilities might arise therefrom.

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Ps were targeted for grand jury investigation in the late 1970s. In 1979 and 1981, R obtained orders from a U.S. District Court pursuant to rule 6(e) of the Federal Rules of Criminal Procedure (rule 6(e)) permitting him to examine transcripts of testimony and materials relating to Ps' business operations obtained from several grand juries to determine whether any civil tax liabilities might arise therefrom. R then lost track of the grand jury materials and did not discover their location until November 1986. R now has custody of the boxes of materials but neither R nor Ps know precisely what…

1Opinion of the Court

OPINION

WILLIAMS, Judge:

These consolidated cases are before us on petitioners’ motion for determination of respondent’s access to grand jury materials. The Commissioner determined the following deficiencies in income tax and additions to tax against petitioners:

Additions to tax

Name of petitioner Docket No. Year Deficiency Sec. 6653(a/3i Sec. 6653(b)

Thomas H. and Dorothy A. Hajecate 498-81 1976 $2,411,821 --- $1,205,911

Thomas M. and Kitten I. Hajecate 499-81 1976 6,946,748 - - - 3,473,374

Linda L. Burch[4] 500-81 1976 5,143

Additions to tax

Name of petitioner Docket No. Year Deficiency Sec.…

2Cases cited13 opinions

  1. Douglas Oil Co. of Cal. v. Petrol Stops NorthwestSupreme Court of the United States · 1979
  2. United States v. Sells Engineering, Inc.Supreme Court of the United States · 1983
  3. United States v. BaggotSupreme Court of the United States · 1983
  4. Kluger v. CommissionerUnited States Tax Court · 1984
  5. United States v. Interstate Dress Carriers, Inc.Court of Appeals for the Second Circuit · 1960

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

3Cited by10 opinions

  1. Bell v. CommissionerUnited States Tax Court · 1988
  2. Kluger v. CommissionerUnited States Tax Court · 1988
  3. Green v. CommissionerUnited States Tax Court · 1993
  4. Bell v. CommissionerUnited States Tax Court · 1988
  5. Bonacci v. CommissionerUnited States Tax Court · 1989

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

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