Legal Opinion

Black Forge, Inc. v. Commissioner

United States Tax Court

Decided June 14, 1982No. Docket Nos. 13138-81, 13139-81, 13140-81PublishedCited by 17 opinions

Local law enforcement officials were aware that the IRS was interested in information concerning Ps, but there was no agreement between such officials and the IRS to exchange such information. Subsequently, a search warrant was issued by a State court, and a search was conducted by such officials in good-faith reliance on such warrant. Ps contend that such search violated their rights under the Fourth Amendment.

Read the full summary

Local law enforcement officials were aware that the IRS was interested in information concerning Ps, but there was no agreement between such officials and the IRS to exchange such information. Subsequently, a search warrant was issued by a State court, and a search was conducted by such officials in good-faith reliance on such warrant. Ps contend that such search violated their rights under the Fourth Amendment. IRS was unaware that the search was to be conducted and did not participate in it. After the search, evidence seized was voluntarily made available to the IRS, and based in part on…

1Opinion of the Court

Simpson, Judge'.

This case is before us on the petitioners’ motion to suppress evidence on the ground that their Fourth Amendment rights were violated during the search in which such evidence was obtained. The issue for decision is whether the evidence is admissible in this case even though such search was illegal.2

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioner, Black Forge, Inc., is a Florida corporation. At the time it filed its petition in this case, it maintained its office in Tampa, Fla. The petitioners, Raymond C. and Shirley Lee…

2Cases cited19 opinions

  1. Mapp v. OhioSupreme Court of the United States · 1961
  2. Weeks v. United StatesSupreme Court of the United States · 1914
  3. United States v. CalandraSupreme Court of the United States · 1974
  4. Elkins v. United StatesSupreme Court of the United States · 1960
  5. Spies v. United StatesSupreme Court of the United States · 1943

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

3Cited by17 opinions

  1. Rowlee v. CommissionerUnited States Tax Court · 1983
  2. Riland v. CommissionerUnited States Tax Court · 1982
  3. Kluger v. CommissionerUnited States Tax Court · 1984
  4. Graham v. CommissionerUnited States Tax Court · 1984
  5. Houser v. CommissionerUnited States Tax Court · 1991

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API