Raymond J. Ryan and Helen Ryan v. Commissioner of Internal Revenue

PERRY, Senior District Judge.

This is an appeal from an order of the United States Tax Court which directed petitioners below, Raymond J. Ryan and Helen Ryan, his wife [hereinafter “the Ryans”], to answer certain interrogatories served by respondent below, the Commissioner of Internal Revenue [hereinafter “the Commissioner”].

In 1964 the Commissioner instituted an investigation of the possible tax liabilities of petitioner Raymond J. Ryan [hereinafter “Ryan”]. This investigation resulted in three successive indictments against Ryan for conspiracy to defraud the Internal Revenue Service,…