Vermouth v. Commissioner
United States Tax Court
Held: Where respondent failed to file an answer within 60 days from the service of the petition, as required by Rule 36(a), Tax Court Rules of Practice and Procedure, and within an additional 60 days permitted by the Court pursuant to an uncontested motion, and where the failure was due to bureaucratic inertia and was not due to circumstances beyond respondent's control, a preclusion order will be entered permitting respondent to file an answer out of time, but striking any…
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Held: Where respondent failed to file an answer within 60 days from the service of the petition, as required by Rule 36(a), Tax Court Rules of Practice and Procedure, and within an additional 60 days permitted by the Court pursuant to an uncontested motion, and where the failure was due to bureaucratic inertia and was not due to circumstances beyond respondent's control, a preclusion order will be entered permitting respondent to file an answer out of time, but striking any matters contained in the answer affirmatively alleging tax fraud. Respondent will not be permitted to introduce evidence…
1Opinion of the Court
Jon W. Vermouth, Petitioner v. Commissioner of Internal Revenue, Respondent
Vermouth v. Commissioner
Docket No. 28158-85
United States Tax Court
88 T.C. 1488; 1987 U.S. Tax Ct. LEXIS 85; 88 T.C. No. 84;
June 17, 1987. June 17, 1987, Filed
Held: Where respondent failed to file an answer within 60 days from the service of the petition, as required by Rule 36(a), Tax Court Rules of Practice and Procedure, and within an additional 60 days permitted by the Court pursuant to an uncontested motion, and where the failure was due to bureaucratic inertia and was not due to circumstances beyond respondent's…
2Cases cited14 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Rowlee v. CommissionerUnited States Tax Court · 1983
- In the Matter of the Complaint of the United States of America, as Owner of the United States Naval Ship Pvt. Joseph F. Merrell, for Exoneration From or Limitation of Liability v. Sumitomo Marine & Fire Insurance Company, Ltd., Etc., Defendants- in the Matter of the Complaint of the United States of America, as Owner of the United States Naval Ship Pvt. Joseph F. Merrell, for Exoneration From or Limitation of Liability, United States of America v. United States Naval Ship Pvt. Joseph F. Merrell and the Vessel "Pearl Venture", United States of America, Counter/claimant-Appellant v. The M/v Pearl Venture, Her Engines, Tackle, Etc., in Rem and Pearl Carriers, Inc., Defendants/counterclaim Sumitomo Marine & Fire Insurance Co., Ltd., a Corp., Plaintiffs v. Pearl Carriers, Inc., and the Vessel Pearl Venture, United States of America v. Sumitomo Marine & Fire Insurance Company, Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1980
- Dusha v. CommissionerUnited States Tax Court · 1984
- George J. Fox and Ruth A. Fox v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1983
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