Gerling International Ins. Co. v. Commissioner
United States Tax Court
In implementation of its prior opinion, see 86 T.C. 468 (1986), the Court determined that petitioner should be precluded from introducing into evidence the books and records of a deemed related Swiss corporation or any information derived therefrom. Held, no change should be made in the two orders of the Court, dated Mar. 12, 1986, and Apr. 9, 1986, and accordingly petitioner's motion for summary judgment is denied.
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In implementation of its prior opinion, see 86 T.C. 468 (1986), the Court determined that petitioner should be precluded from introducing into evidence the books and records of a deemed related Swiss corporation or any information derived therefrom. Held, no change should be made in the two orders of the Court, dated Mar. 12, 1986, and Apr. 9, 1986, and accordingly petitioner's motion for summary judgment is denied. Held, further, respondent's motion for summary judgment is granted.
1Opinion of the Court
OPINION
TANNENWALD, Judge:
This case is again before us on cross motions for summary judgment. The parties agree (and we concur) that, in the present posture of the case, there are no genuine issues of material fact involved; consequently, we may dispose of the case by decision as a matter of law. Rule 121, Tax Court Rules of Practice and Procedure.
The factual background, which provides the foundation for the motions herein, is largely set forth in our prior opinion, 86 T.C. 468 (1986), and will not be repeated herein. Rather, we will set forth what has occurred since the memorandum sur order,…
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- Raul Llorente v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
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