Legal Opinion

Levy v. Commissioner

United States Tax Court

Decided October 20, 1986No. Docket Nos. 31285-81, 234-82, 27133-82, 5553-84, 34739-84PublishedCited by 25 opinions

The instant cases were set for trial on numerous occasions and continued. Petitioners never stipulated any facts with respondent and, despite warnings from the Court, never prepared for trial. Held, the cases are dismissed for failure properly to prosecute under Rule 123(b) of the Court's Rules of Practice and Procedure.

1Opinion of the Court

OPINION

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners’ Federal income tax as follows:

Docket No. Taxable year Deficiency

31285-81 1977 $25,400

1978 13,767

1979 10,135

234-82 1979 21,908

27133-82 1980 29,582

5553-84 1981 11,590

34739-84 1975 2,844

1976 4,106

1977 8,347

1978 22,294

1979 2,324

1980 7,027

These cases were called for trial at the call of the calendar in Miami, Florida, on February 24, 1986. That was the beginning date of a 2-week trial session in Miami. Parties in other cases scheduled for trial previously Contacted the Court to ask for dates certain due to the number of…

2Cases cited7 opinions

  1. Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
  2. Hatfield v. CommissionerUnited States Tax Court · 1977
  3. Ralph Freedson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1978
  4. Brooks v. CommissionerUnited States Tax Court · 1984
  5. Dusha v. CommissionerUnited States Tax Court · 1984

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

3Cited by25 opinions

  1. Harper v. CommissionerUnited States Tax Court · 1992
  2. Rollercade, Inc. v. CommissionerUnited States Tax Court · 1991
  3. Leach v. CommissionerUnited States Tax Court · 1993
  4. Fifer v. CommissionerUnited States Tax Court · 1993
  5. Voss v. CommissionerUnited States Tax Court · 1989

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

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