Davis v. Commissioner
United States Tax Court
Rules 70 and 72, Tax Court Rules of Practice and Procedure. -- The substantive issues to be decided in this case are whether the value of books received by the petitioner-husband from West Publishing Co. was includable in his income and whether it was properly deductible when they were later donated to the University of Chicago.
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Rules 70 and 72, Tax Court Rules of Practice and Procedure. -- The substantive issues to be decided in this case are whether the value of books received by the petitioner-husband from West Publishing Co. was includable in his income and whether it was properly deductible when they were later donated to the University of Chicago. To ascertain if any taxpayers have received a ruling inconsistent with the determination made in his case, allegedly to show that respondent discriminated against him, petitioner seeks discovery of all private letter rulings issued by the respondent which are…
1Opinion of the Court
OPINION
Dawson, Judge:
On September 12, 1977, the petitioner filed, pursuant to Rule 70, Tax Court Rules of Practice and Procedure, a motion for discovery of Internal Revenue Service private letter rulings contained in the “reference” files which are of general application concerning the deductibility of charity contributions of property that taxpayers have received by gift or otherwise without paying an income tax on receipt of the property. On October 17, 1977, respondent filed a motion for a protective order to relieve him from complying with petitioner’s motion for discovery. Arguments on…
2Cases cited17 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Dixon v. United StatesSupreme Court of the United States · 1965
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
- Davis v. CommissionerUnited States Tax Court · 1976
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3Cited by11 opinions
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
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- AmerGen Energy Co. ex rel. Exelon Generation Co. v. United StatesUnited States Court of Federal Claims · 2010
- Alling v. CommissionerUnited States Tax Court · 1994
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