Legal Opinion

Director v. Commissioner

United States Tax Court

Decided June 13, 1988No. Docket Nos. 15877-84; 15878-84Unpublished

In 1979, pursuant to subpoena, P appeared as a witness before a New York State grand jury investigating the business practices of a hospital, an institution for which P had provided plumbing an heating services. P's books and records and other financial materials had been subpoenaed previously by the grand jury.

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In 1979, pursuant to subpoena, P appeared as a witness before a New York State grand jury investigating the business practices of a hospital, an institution for which P had provided plumbing an heating services. P's books and records and other financial materials had been subpoenaed previously by the grand jury. Before the grand jury was discharged, the New York State Special Prosecutor's office sent a letter to the Criminal Intelligence Division, Internal Revenue Service, informing respondent that P had underreported his income for taxable years 1973, 1975 investigation of P's income tax…

1Opinion of the Court

NATHAN DIRECTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; NATHAN DIRECTOR AND ANNE DIRECTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Director v. Commissioner

Docket Nos. 15877-84; 15878-84.

United States Tax Court

T.C. Memo 1988-256; 1988 Tax Ct. Memo LEXIS 285; 55 T.C.M. (CCH) 1059; T.C.M. (RIA) 88256;

June 13, 1988

In 1979, pursuant to subpoena, P appeared as a witness before a New York State grand jury investigating the business practices of a hospital, an institution for which P had provided plumbing an heating services. P's books and records and other…

2Cases cited84 opinions

  1. United States v. WadeSupreme Court of the United States · 1967
  2. United States v. LeonSupreme Court of the United States · 1984
  3. United States v. NixonSupreme Court of the United States · 1974
  4. United States v. CalandraSupreme Court of the United States · 1974
  5. Alderman v. United StatesSupreme Court of the United States · 1969

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