Lutz v. Commissioner
United States Tax Court
P has totally and willfully failed to produce documents despite a specific order of this Court directing him to do so. Held, P's failure constitutes a default and judgment therefor is appropriate respecting the income tax deficiencies and the additions to the tax under sec. 6654, I.R.C. 1954. Rule 104(c)(3), Tax Court Rules of Practice and Procedure.Held further, P is liable for the additions to tax for fraud under sec. 6653(b), I.R.C. 1954. Rule 104(c)(1), Tax Court Rules…
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P has totally and willfully failed to produce documents despite a specific order of this Court directing him to do so. Held, P's failure constitutes a default and judgment therefor is appropriate respecting the income tax deficiencies and the additions to the tax under sec. 6654, I.R.C. 1954. Rule 104(c)(3), Tax Court Rules of Practice and Procedure.Held further, P is liable for the additions to tax for fraud under sec. 6653(b), I.R.C. 1954. Rule 104(c)(1), Tax Court Rules of Practice and Procedure.Durovic v. Commissioner,84 T.C. 101 (1985), followed.
1Opinion of the Court
LEONARD A. LUTZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lutz v. Commissioner
Docket No. 23618-83.
United States Tax Court
T.C. Memo 1986-13; 1986 Tax Ct. Memo LEXIS 592; 51 T.C.M. (CCH) 262; T.C.M. (RIA) 86013;
January 13, 1986.
P has totally and willfully failed to produce documents despite a specific order of this Court directing him to do so. Held, P's failure constitutes a default and judgment therefor is appropriate respecting the income tax deficiencies and the additions to the tax under sec. 6654, I.R.C. 1954. Rule 104(c)(3), Tax Court Rules of Practice and Procedure.Held…
2Cases cited25 opinions
- National Hockey League v. Metropolitan Hockey Club, Inc.Supreme Court of the United States · 1976
- Societe Internationale Pour Participations Industrielles Et Commerciales, S. A. v. RogersSupreme Court of the United States · 1958
- Hammond Packing Co. v. ArkansasSupreme Court of the United States · 1909
- Cupp v. CommissionerUnited States Tax Court · 1975
- William H. And Avilda L. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
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