Bolton v. Commissioner
United States Tax Court
R issued a notice of deficiency on May 26, 1988. A timely petition was filed on June 20, 1988. Ps alleged in the petition that the period of limitations expired under sec. 6501, I.R.C. 1954. R's answer was due to be filed on Aug. 19, 1988. R's counsel, not having received his administrative file, filed on Aug. 8, 1988, a motion to extend the time for filing an answer.
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R issued a notice of deficiency on May 26, 1988. A timely petition was filed on June 20, 1988. Ps alleged in the petition that the period of limitations expired under sec. 6501, I.R.C. 1954. R's answer was due to be filed on Aug. 19, 1988. R's counsel, not having received his administrative file, filed on Aug. 8, 1988, a motion to extend the time for filing an answer. Held, R failed to establish that he exercised reasonable diligence to ensure that his answer would be filed within the 60-day period provided by Rule 36(a), Tax Court Rules of Practice and Procedure.Held, further, P's counsel…
1Opinion of the Court
OPINION
Chabot, Judge:
Respondent’s motion to extend time within which to answer filed herein was assigned to Special Trial Judge Peter J. Panuthos.1 This case came before the Court on respondent’s motion to extend time within which to answer. After a review of the record, we agree with and adopt his opinion as set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
This case came before the Court on respondent’s motion to extend time within which to answer. A notice of deficiency was issued to petitioners on May 26, 1988, determining a deficiency for the taxable year…
2Cases cited4 opinions
- Vermouth v. CommissionerUnited States Tax Court · 1987
- Betz v. CommissionerUnited States Tax Court · 1988
- Versteeg v. CommissionerUnited States Tax Court · 1988
- Rea v. CommissionerUnited States Tax Court · 1973
3Cited by6 opinions
- Leach v. CommissionerUnited States Tax Court · 1993
- New v. CommissionerUnited States Tax Court · 1989
- Bolton v. CommissionerUnited States Tax Court · 1990
- Bolton v. CommissionerUnited States Tax Court · 1989
- New v. CommissionerUnited States Tax Court · 1989
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