Santa Maria v. Commissioner
United States Tax Court
R issued a foreign document request under sec. 982, I.R.C., to a corporation that is solely owned by Ps. No similar request under sec. 982, I.R.C., was addressed to Ps.
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R issued a foreign document request under sec. 982, I.R.C., to a corporation that is solely owned by Ps. No similar request under sec. 982, I.R.C., was addressed to Ps. Ps supplied the documents in question within the time allotted by the Court's discovery rules, but not within 90 days of receiving the sec. 982, I.R.C., request. 1. Held: Admission of the documents presented by Ps is not prohibited by sec. 982 I.R.C. 2. Held, further, Ps did not understate their taxable income by $ 136,245. 3. Held, further, Ps received unreported interest income of $ 17. 4. Held, further, Ps are not subject…
1Opinion of the Court
CYRUS T. SANTA MARIA AND LUISA J. SANTA MARIA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Santa Maria v. Commissioner
Docket No. 1290-92
United States Tax Court
T.C. Memo 1994-622; 1994 Tax Ct. Memo LEXIS 629; 68 T.C.M. (CCH) 1468;
December 19, 1994, Filed
Decision will be entered under Rule 155.
R issued a foreign document request under sec. 982, I.R.C., to a corporation that is solely owned by Ps. No similar request under sec. 982, I.R.C., was addressed to Ps. Ps supplied the documents in question within the time allotted by the Court's discovery rules, but not within 90 days of…
2Cases cited14 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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