Legal Opinion

Malat v. Commissioner

United States Tax Court

Decided May 31, 1960No. Docket Nos. 63976, 63977, 63978, 63979PublishedCited by 15 opinions

Held, petitioners' motions for judgments against themselves to be based upon findings of fact they concede, are denied, and, since petitioners offered no evidence, judgments will be rendered based upon petitioners' failure of proof.

1Opinion of the Court

OPINION.

MulRONet, Judge:

When these consolidated dockets were called for trial neither petitioners nor respondent offered any evidence. Petitioners filed motions in all of these dockets which began with the following language:

MOTION

Petitioners move the court for judgment on the pleadings, with the resulting deficiency to be determined under Bule 50, * * *

Respondent determined deficiencies in income tax and additions to tax, as follows:

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Respondent, in the several notices of deficiency, after setting forth the amounts of deficiency indicated above, attached several schedules showing…

2Cited by15 opinions

  1. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
  2. Church of Scientology v. CommissionerUnited States Tax Court · 1984
  3. Doggett v. CommissionerUnited States Tax Court · 1976
  4. Lesser v. CommissionerUnited States Tax Court · 1967
  5. Malat v. Commissioner of Internal RevEnueCourt of Appeals for the Ninth Circuit · 1962

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