Anonymous v. Commissioner
United States Tax Court
P requested a PLR from R. R informed P that he would be issuing a PLR adverse to P's interests. P declined to withdraw the request for a PLR. Before R publicly released the PLR, P petitioned this Court, alleging that the PLR was arbitrary and capricious and that R failed to delete certain terms in the PLR that tended to identify P. P asks that we order R not to disclose the PLR or, in the alternative, order R to delete certain terms from the PLR.
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P requested a PLR from R. R informed P that he would be issuing a PLR adverse to P's interests. P declined to withdraw the request for a PLR. Before R publicly released the PLR, P petitioned this Court, alleging that the PLR was arbitrary and capricious and that R failed to delete certain terms in the PLR that tended to identify P. P asks that we order R not to disclose the PLR or, in the alternative, order R to delete certain terms from the PLR. R moved for summary judgment and argues that this Court lacks jurisdiction to prevent R from disclosing the PLR at issue and that none of the terms…
1Opinion of the Court
OPINION
Goeke, Judge:
This matter is before the Court on respondent’s motion for summary judgment filed pursuant to Rule 121. For the reasons stated herein, we shall grant in part and deny in part respondent’s motion.
Background
On October 1, 2004, petitioner submitted a request for a private letter ruling (plr). On September 17, 2007, respondent contacted petitioner to inform petitioner that respondent intended to issue the PLR with a determination adverse to petitioner’s request. Respondent informed petitioner’s counsel that petitioner could withdraw the request, but petitioner declined. On…
2Cases cited12 opinions
- Califano v. SandersSupreme Court of the United States · 1977
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
7 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
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- Whistleblower 14106-10W v. CommissionerUnited States Tax Court · 2011
- Kaufman v. CommissionerUnited States Tax Court · 2010
- Meidinger v. CommissionerCourt of Appeals for the D.C. Circuit · 2014
6 more not listed; retrieve them via the Exa API.