Legal Opinion

Ash v. Commissioner

United States Tax Court

Decided March 11, 1991No. Docket No. 30585-89PublishedCited by 24 opinions

Held, with respect to the summonses issued both before and after petitioner filed her petition to this Court, petitioner's motion for a protective order will be denied. Universal Manufacturing Co. v. Commissioner, 93 T.C. 589 (1989), and Westreco, Inc. v. Commissioner, T.C. Memo. 1990-501 (which relied on Universal Manufacturing Co.), modified.

1Opinion of the Court

OPINION

WRIGHT, Judge:

This matter is before the Court on petitioner’s motion for protective order filed on July 6, 1990. Petitioner seeks a protective order under Rule 1031 to restrict respondent’s use of information obtained through administrative summonses.

By notices of deficiency dated October 10, 1989, respondent determined the following deficiencies in and additions to petitioner’s Federal income tax:

_Additions to tax_

Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661

1983 $37,060 $1,853 1

1985 6,608,527 330,426 1 $1,652,132

1 50 percent of the interest due on the deficiencies.

In a…

2Cases cited15 opinions

  1. Seattle Times Co. v. RhinehartSupreme Court of the United States · 1984
  2. United States v. MorganSupreme Court of the United States · 1939
  3. Theard v. United StatesSupreme Court of the United States · 1957
  4. Eash v. Riggins Trucking Inc.Court of Appeals for the Third Circuit · 1985
  5. Don Kirshner, and Schumaier, Roberts & McKinsey v. Uniden Corporation of AmericaCourt of Appeals for the Ninth Circuit · 1988

10 more not listed; retrieve them via the Exa API.

3Cited by24 opinions

  1. United States v. Administrative Enterprises, Incorporated, Principal Services, Incorporated, Zion Ventures, IncorporatedCourt of Appeals for the Seventh Circuit · 1995
  2. Monetary II Limited Partnership, J. Thomas Hannan, Tax Matters Partner v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
  3. Paa Management, Ltd. v. United StatesCourt of Appeals for the Second Circuit · 1992
  4. Bagby v. CommissionerUnited States Tax Court · 1994
  5. DiLeo v. CommissionerUnited States Tax Court · 1991

19 more not listed; retrieve them via the Exa API.

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