Legal Opinion
Jeffrey and Virginia M. Hambarian v. Commissioner
United States Tax Court
Decided June 13, 2002No. 11856-99, 7973-00, 3042-01, 3101-01Unknown
1Opinion of the Court
118 T.C. No. 35
UNITED STATES TAX COURT JEFFREY HAMBARIAN AND VIRGINIA M. HAMBARIAN, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 11856-99, 7973-00, Filed June 13, 2002. 3042-01, 3101-01. P is a defendant in a criminal proceeding. The transactions and circumstances which gave rise to the criminal proceeding were also the predicate for R’s civil tax determination. P’s criminal defense attorney selected 100,000 pages of documents from a much larger universe of documents that were in the possession of the prosecuting attorney. The documents were converted by…
2Cases cited10 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- Sporck v. PeilCourt of Appeals for the Third Circuit · 1985
- In Re San Juan Dupont Plaza Hotel Fire Litigation. Petition of the Plaintiffs' Steering CommitteeCourt of Appeals for the First Circuit · 1988
- Branerton Corp. v. CommissionerUnited States Tax Court · 1974
- Washington Bancorporation v. SaidDistrict Court, District of Columbia · 1992
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