Terpil v. Commissioner
United States Tax Court
R issued a notice of deficiency to Ps based upon information obtained from grant jury proceedings pursuant to Federal District Court order under Rule 6(e), Fed. R. Crim. P. Both Ps lived outside the U.S. when petition was filed.
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R issued a notice of deficiency to Ps based upon information obtained from grant jury proceedings pursuant to Federal District Court order under Rule 6(e), Fed. R. Crim. P. Both Ps lived outside the U.S. when petition was filed. P-W subsequently returned, but P-H remains fugitive from justice.Ps moved to quash statutory notice, set aside erroneous assessment and enter judgment for Ps, and to suppress, shift burden of going forward and to strike, all based upon retroactive application of principles in United States v. Baggot,463 U.S. 476 (1983), and United States v. Sells Engineering, Inc.,463…
1Opinion of the Court
MARILLYN D. TERPIL AND FRANCIS E. TERPIL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Terpil v. Commissioner
Docket No. 22903-80.
United States Tax Court
T.C. Memo 1985-350; 1985 Tax Ct. Memo LEXIS 283; 50 T.C.M. (CCH) 438; T.C.M. (RIA) 85350;
July 16, 1985.
R issued a notice of deficiency to Ps based upon information obtained from grant jury proceedings pursuant to Federal District Court order under Rule 6(e), Fed. R. Crim. P. Both Ps lived outside the U.S. when petition was filed. P-W subsequently returned, but P-H remains fugitive from justice.Ps moved to quash statutory notice,…
2Cases cited11 opinions
- United States v. Sells Engineering, Inc.Supreme Court of the United States · 1983
- Molinaro v. New JerseySupreme Court of the United States · 1970
- United States v. BaggotSupreme Court of the United States · 1983
- Sally Conforte v. Commissioner of Internal Revenue, Joseph Conforte v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Kluger v. CommissionerUnited States Tax Court · 1984
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