Marcus v. Commissioner
United States Tax Court
Despite repeated orders of the Court, petitioners failed, over a period of several years, to answer respondent's interrogatories, to respond to respondent's request for admissions, or to cooperate in the stipulation process.
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Despite repeated orders of the Court, petitioners failed, over a period of several years, to answer respondent's interrogatories, to respond to respondent's request for admissions, or to cooperate in the stipulation process. Held, on respondent's motion for sanctions under Rule 104(c), Tax Court Rules of Practice and Procedure, the allegations of error and allegations of fact in petitioners' petitions for 1959, 1960, and 1961 are stricken, and respondent's affirmative allegations of fraud in his answer and amendment to answer to petitioner-husband's petition are deemed admitted. Held,…
1Opinion of the Court
OPINION
Hall, Judge:
These proceedings arise on this Court’s order dated April 7, 1978, directing petitioners to file a response with the Court showing why the matters set forth in respondent’s proposed additional supplemental stipulation of facts should not be deemed admitted for purposes of these cases, and on respondent’s motion filed April 10, 1978, to impose sanctions under Rule 104 (Tax Court Rules of Practice and Procedure) and requesting partial summary judgment.
In notices of deficiency dated August 9, 1972, respondent determined the following deficiencies and additions to tax:1
Docket…
2Cases cited10 opinions
- Otsuki v. CommissionerUnited States Tax Court · 1969
- Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
- Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Hopkins v. BaconSupreme Court of the United States · 1930
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3Cited by112 opinions
- Doncaster v. CommissionerUnited States Tax Court · 1981
- Truesdell v. Comm'rUnited States Tax Court · 1987
- Kotmair v. CommissionerUnited States Tax Court · 1986
- Donald G. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Smith v. CommissionerUnited States Tax Court · 1988
107 more not listed; retrieve them via the Exa API.