Legal Opinion

Phelps v. Commissioner

United States Tax Court

Decided July 15, 1974No. Docket No. 1180-71Published

Rule 70(c). Tax Court Rules of Practice and Procedure. -- Petitioners seek the production of memoranda prepared by agents of the Internal Revenue Service following interviews of petitioners during the course of an investigation of petitioners' income tax returns for the years in controversy. Held, on the facts of record, the memoranda of interviews are statements of parties to this proceeding and must be produced.

1Opinion of the Court

Howard C. Phelps and Geraldine Phelps, Petitioners v. Commissioner of Internal Revenue, Respondent

Phelps v. Commissioner

Docket No. 1180-71

United States Tax Court

62 T.C. 513; 1974 U.S. Tax Ct. LEXIS 76; 62 T.C. No. 57; 18 Fed. R. Serv. 2d (Callaghan) 1525;

July 15, 1974, Filed

Rule 70(c). Tax Court Rules of Practice and Procedure. -- Petitioners seek the production of memoranda prepared by agents of the Internal Revenue Service following interviews of petitioners during the course of an investigation of petitioners' income tax returns for the years in controversy. Held, on the facts of record,…

2Cases cited14 opinions

  1. Hickman v. TaylorSupreme Court of the United States · 1947
  2. Palermo v. United StatesSupreme Court of the United States · 1959
  3. United States v. AugenblickSupreme Court of the United States · 1969
  4. United States v. Thomas McKeever and Lawrence MorrisonCourt of Appeals for the Second Circuit · 1959
  5. United States v. Harlan Alexander BlackburnCourt of Appeals for the Fifth Circuit · 1971

9 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