Centre for International Understanding v. Commissioner
United States Tax Court
Held, in these circumstances, consolidation of declaratory judgment case with deficiency case not permitted.
1Opinion of the Court
OPINION
CANTREL, Special Trial Judge:
These cases are presently before the Court2 on petitioners’ motion to consolidate filed in each of the above cases on August 6, 1984, pursuant to Rule 141(a).3 Respondent agrees that these cases be consolidated.
The motion presents an issue of first impression in that it involves consolidating a declaratory judgment case with a case that includes transferee liability and excise and income tax deficiencies determined against the Centre itself and three directors individually. (The latter case, for clarity, will hereinafter be referred to as the deficiency…
2Cases cited7 opinions
- Houston Lawyer Referral Service, Inc. v. CommissionerUnited States Tax Court · 1978
- Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1949
- Odend'hal v. CommissionerUnited States Tax Court · 1980
- Western Catholic Church v. CommissionerUnited States Tax Court · 1979
- New Community Senior Citizen Housing Corp. v. CommissionerUnited States Tax Court · 1979
2 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Z Street v. John KoskinenCourt of Appeals for the D.C. Circuit · 2015
- Eiges v. CommissionerUnited States Tax Court · 1993
- Centre for International Understanding v. CommissionerUnited States Tax Court · 1985
- Eiges v. CommissionerUnited States Tax Court · 1993