Ryan v. Commissioner
United States Tax Court
Petitioners were ordered by this Court to answer respondent's interrogatories but they refused to do so. Petitioners appealed from that order but the appeal was dismissed because our order was not a final order. Pending the appeal, petitioners were granted use immunity by an order of the U.S. District Court for the District of Columbia. Subsequently petitioners were again ordered by this Court to answer the interrogatories but they again refused to do so.
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Petitioners were ordered by this Court to answer respondent's interrogatories but they refused to do so. Petitioners appealed from that order but the appeal was dismissed because our order was not a final order. Pending the appeal, petitioners were granted use immunity by an order of the U.S. District Court for the District of Columbia. Subsequently petitioners were again ordered by this Court to answer the interrogatories but they again refused to do so. Held: Petitioners may not avoid answering the interrogatories on a claim of privilege under the fifth amendment to the U.S. Constitution.…
1Opinion of the Court
OPINION
Drennen, Judge:
This protracted litigation, which is still in the pretrial stages, had its genesis in the petition filed by petitioners in this Court in 1969 asking the Court to redetermine the deficiencies in petitioners’ joint income taxes for the years 1958 through 1962, totaling $4,375,868.48, and additions to tax for fraud for each of those years totaling $2,312,322.35.
As reflected in the opinion of this Court found in Raymond J. Ryan, 58 T.C. 107, on October 16, 1969, the Internal Revenue Service of the United States requested from the Federal Tax Administration of Switzerland on…
2Cases cited31 opinions
- United States v. United Mine Workers of AmericaSupreme Court of the United States · 1947
- Kastigar v. United StatesSupreme Court of the United States · 1972
- Hoffman v. United StatesSupreme Court of the United States · 1951
- Gompers v. Bucks Stove & Range Co.Supreme Court of the United States · 1911
- United States v. JanisSupreme Court of the United States · 1976
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3Cited by40 opinions
- McCoy v. CommissionerUnited States Tax Court · 1981
- Coulter v. CommissionerUnited States Tax Court · 1984
- Burns v. CommissionerUnited States Tax Court · 1981
- Williams v. Comm'rUnited States Tax Court · 2002
- Bert v. Comptroller of the TreasuryCourt of Special Appeals of Maryland · 2013
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