Bolton v. Commissioner
United States Tax Court
R issued a notice of deficiency on May 26, 1988. A timely petition was filed on June 20, 1988. Ps alleged in the petition that the period of limitations expired under sec. 6501, I.R.C. 1954. R's answer was due to be filed on Aug. 19, 1988. R's counsel, not having received his administrative file, filed on Aug. 8, 1988, a motion to extend the time for filing an answer.
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R issued a notice of deficiency on May 26, 1988. A timely petition was filed on June 20, 1988. Ps alleged in the petition that the period of limitations expired under sec. 6501, I.R.C. 1954. R's answer was due to be filed on Aug. 19, 1988. R's counsel, not having received his administrative file, filed on Aug. 8, 1988, a motion to extend the time for filing an answer. Held, R failed to establish that he exercised reasonable diligence to ensure that his answer would be filed within the 60-day period provided by Rule 36(a), Tax Court Rules of Practice and Procedure.Held, further, P's counsel…
1Opinion of the Court
Edgar A. Bolton and Judy R. Bolton, Petitioners v. Commissioner of Internal Revenue, Respondent
Bolton v. Commissioner
Docket No. 14125-88
United States Tax Court
92 T.C. 656; 1989 U.S. Tax Ct. LEXIS 40; 92 T.C. No. 36;
March 28, 1989; As corrected June 22, 1989 March 28, 1989, Filed
An order granting respondent's motion will be will be issued.
R issued a notice of deficiency on May 26, 1988. A timely petition was filed on June 20, 1988. Ps alleged in the petition that the period of limitations expired under sec. 6501, I.R.C. 1954. R's answer was due to be filed on Aug. 19, 1988. R's counsel, not…
2Cases cited5 opinions
- Vermouth v. CommissionerUnited States Tax Court · 1987
- Betz v. CommissionerUnited States Tax Court · 1988
- Versteeg v. CommissionerUnited States Tax Court · 1988
- Rea v. CommissionerUnited States Tax Court · 1973
- Bolton v. CommissionerUnited States Tax Court · 1989