Morrison v. Commissioner
United States Tax Court
Held, petitioners' motion under Rule 90(c), Tax Court Rules of Practice and Procedure, to enlarge the time in which to answer respondent's request for admissions, will be denied as such and also as a motion under Rule 90(e) to withdraw or modify deemed admissions. Held, further, respondent's motion for summary judgment under Rule 121 will be granted.
1Opinion of the Court
OPINION
Shields, Judge:
Respondent determined tijat there was a deficiency of $975 in the income tax due from the petitioners for 1978. The deficiency resulted from the respondent’s disallowance of a miscellaneous deduction claimed by the petitioners in the amount of $13,089 allegedly paid by them for information, advice, and/or forms to be used in establishing a so-called family trust.
On November 23, 1981, the petitioners who were then residents of Illinois filed a petition in this Court seeking a redetermination of the deficiency. The petitioners, however, failed to set forth in their…
2Cases cited12 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- United States v. Diebold, Inc.Supreme Court of the United States · 1962
- Ralph Freedson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1978
- Freedson v. CommissionerUnited States Tax Court · 1975
- Creedon v. TaubmanDistrict Court, N.D. Ohio · 1947
7 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- Sierra Club v. CommissionerUnited States Tax Court · 1994
- Castleton v. Comm'rUnited States Tax Court · 2005
- Adams v. CommissionerUnited States Tax Court · 1990
- Morrison v. CommissionerUnited States Tax Court · 1987
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