Legal Opinion

Burton v. Commissioner

United States Tax Court

Decided February 29, 1984No. Docket No. 11843-83Unpublished

Petitioner has failed to produce documents and answer interrogatories despite a specific Order of this Court directing him to do so. Held, petitioner's failure constitutes a default under the circumstances of this case. Respondent's Motion to Impose Sanctions, seeking a judgment for default under Rule 104(c)(3), Tax Court Rules of Practice and Procedure, is granted.

1Opinion of the Court

HOWARD BURTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Burton v. Commissioner

Docket No. 11843-83.

United States Tax Court

T.C. Memo 1984-99; 1984 Tax Ct. Memo LEXIS 576; 47 T.C.M. (CCH) 1192; T.C.M. (RIA) 84099;

February 29, 1984.

Petitioner has failed to produce documents and answer interrogatories despite a specific Order of this Court directing him to do so. Held, petitioner's failure constitutes a default under the circumstances of this case. Respondent's Motion to Impose Sanctions, seeking a judgment for default under Rule 104(c)(3), Tax Court Rules of Practice and…

2Cases cited14 opinions

  1. McCoy v. CommissionerUnited States Tax Court · 1981
  2. Norman E. McCoy and Mary Louise McCoy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  3. Ralph Freedson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1978
  4. Freedson v. CommissionerUnited States Tax Court · 1975
  5. Branerton Corp. v. CommissionerUnited States Tax Court · 1974

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