Bosurgi v. Commissioner
United States Tax Court
R seeks a default judgment against Ps pursuant to Rule 123(a), Tax Court Rules of Practice and Procedure. R alleges that Ps are liable for determined amounts of estate tax and additions to tax as transferees of the assets of an estate. Ps did not appear for their scheduled trial at which time R asked the Court to enter a default judgment. Ps' counsel withdrew as counsel of record in 1976. Ps have not responded to this Court's orders or communicated with this Court.
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R seeks a default judgment against Ps pursuant to Rule 123(a), Tax Court Rules of Practice and Procedure. R alleges that Ps are liable for determined amounts of estate tax and additions to tax as transferees of the assets of an estate. Ps did not appear for their scheduled trial at which time R asked the Court to enter a default judgment. Ps' counsel withdrew as counsel of record in 1976. Ps have not responded to this Court's orders or communicated with this Court. Held, entry of a default pursuant to Rule 123(a) is appropriate in these cases. Held, further, entry of a default has the effect…
1Opinion of the Court
Leone Bosurgi, Transferee of the Estate of Adriana Bosurgi, Deceased, Petitioner v. Commissioner of Internal Revenue, Respondent; Emilio Bosurgi, Transferee of the Estate of Adriana Bosurgi, Deceased, Petitioner v. Commissioner of Internal Revenue, Respondent
Bosurgi v. Commissioner
Docket Nos. 5250-71, 5251-71
United States Tax Court
87 T.C. 1403; 1986 U.S. Tax Ct. LEXIS 4; 84 T.C. No. 80; 87 T.C. No. 80;
December 23, 1986, Filed
R seeks a default judgment against Ps pursuant to Rule 123(a), Tax Court Rules of Practice and Procedure. R alleges that Ps are liable for determined amounts of estate…
Also in this document: Dissent.
2Cases cited18 opinions
- Nishimatsu Construction Co., Ltd. v. Houston National Bank, Defendant-Third Party v. Jack D. Baize, Third PartyCourt of Appeals for the Third Circuit · 1975
- Commissioner v. SternSupreme Court of the United States · 1958
- Hughes Tool Co. v. Trans World Airlines, Inc.Supreme Court of the United States · 1973
- Trans World Airlines, Inc. v. Howard R. Hughes, and Hughes Tool Company and Raymond M. HollidayCourt of Appeals for the Second Circuit · 1971
- Doncaster v. CommissionerUnited States Tax Court · 1981
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