Flying Tigers Oil Co. v. Commissioner
United States Tax Court
Respondent moved to prohibit the introduction of documents pursuant to sec. 982, I.R.C. 1954. Respondent has met all of the requirements of sec. 982. Petitioner has failed to prove its failure was due to reasonable cause. Held, respondent's motion is granted.
1Opinion of the Court
OPINION
Parr, Judge:
This case is currently before us on respondent’s motion to prohibit the introduction of documents pursuant to section 9821 filed May 2, 1989.
For purposes of this case we find petitioner was an Arizona corporation when it filed its petition. On April 1, 1985, petitioner filed a 1984 U.S. Short-Form Corporate Income Tax Return, Form 1120-A. On the return, petitioner reported no gross receipts or cost of goods sold and special deductions of $12,545.04. The attached balance sheet lists assets and liabilities in the millions of dollars. For example, petitioner reported…
2Cases cited6 opinions
- Glass v. CommissionerUnited States Tax Court · 1986
- Gerling International Insurance Co. v. Commissioner of Internal Revenue. Appeal of Gerling International Insurance CoCourt of Appeals for the Third Circuit · 1988
- Clemon J. And Ivy C. Herrington v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Gerling International Ins. Co. v. CommissionerUnited States Tax Court · 1986
- Gerling International Ins. Co. v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Flying Tigers Oil Co. v. CommissionerUnited States Tax Court · 1989
- Santa Maria v. CommissionerUnited States Tax Court · 1994