Westreco, Inc. v. Commissioner
United States Tax Court
Agents of the Commissioner examined the income tax returns of petitioner and related corporations for taxable years subsequent to the years before the Court. One of the issues raised in the examination is identical to the issue involved in this proceeding. Counsel for respondent in this proceeding actively participated in the examination of the returns for subsequent years.
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Agents of the Commissioner examined the income tax returns of petitioner and related corporations for taxable years subsequent to the years before the Court. One of the issues raised in the examination is identical to the issue involved in this proceeding. Counsel for respondent in this proceeding actively participated in the examination of the returns for subsequent years. Held, the activities of respondent's counsel and the use of administrative summonses of petitioner's employees in the subsequent years' audit undermines the Court's Rules on discovery. Title VII, Tax Court Rules of…
1Opinion of the Court
WESTRECO, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Westreco, Inc. v. Commissioner
Docket No. 24078-88
United States Tax Court
T.C. Memo 1990-501; 1990 Tax Ct. Memo LEXIS 554; 60 T.C.M. (CCH) 824; T.C.M. (RIA) 90501;
September 20, 1990, Filed
Agents of the Commissioner examined the income tax returns of petitioner and related corporations for taxable years subsequent to the years before the Court. One of the issues raised in the examination is identical to the issue involved in this proceeding. Counsel for respondent in this proceeding actively participated in the examination…
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