Legal Opinion

Dressler v. Commissioner

United States Tax Court

Decided May 6, 1971No. Docket No. 104-71SPublishedCited by 10 opinions

Respondent's Motion to Deny Petitioner's Request for Conduct of Proceedings Under Section 7463, I.R.C. 1954, filed at the time he filed his answer in accordance with the provisions of Rule 36(c)(2), is denied since respondent has not shown the issue raised by the petition to be one of importance which will establish a principle of law applicable to other tax cases.

1Opinion of the Court

OPINION

Scott, Judge:

On January 4,1971, the petition in the above-entitled case was filed. The deficiency in dispute was stated to be for the year 1967 and in the amount of $498.20, the entire amount of deficiency for the year 1967 as shown by the notice of deficiency attached to the petition.

The petition was served on respondent on January 14,1971, and. on that same date there was served on petitioners, with a copy to respondent, a Notice to Petitioners Plaving a Small Tax Case, which stated in part as follows:

In small tax cases such as yours, Rule 36 provides that you may make a request to…

2Cases cited5 opinions

  1. Commissioner v. KorellSupreme Court of the United States · 1950
  2. Salkov v. CommissionerUnited States Tax Court · 1966
  3. Lawrence v. CommissionerUnited States Tax Court · 1968
  4. W. Astor Kirk and Vivian M. Kirk v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1970
  5. Kirk v. CommissionerUnited States Tax Court · 1968

3Cited by10 opinions

  1. Kallich v. CommissionerUnited States Tax Court · 1987
  2. Bruno v. CommissionerUnited States Tax Court · 1979
  3. Hubbard v. Comm'rUnited States Tax Court · 1987
  4. Bruno v. CommissionerUnited States Tax Court · 1979
  5. Dressler v. CommissionerUnited States Tax Court · 1971

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