Legal Opinion

Riland v. Commissioner

United States Tax Court

Decided August 2, 1982No. Docket No. 6854-79Published

1. The Department of Justice's files relating to petitioner-husband were lost in 1973, but subsequently recovered. Held, the loss of such files does not constitute a violation of due process entitling petitioners to summary judgment or suppression of evidence. 2. Petitioner-husband was tried and acquitted of criminal tax fraud in May 1974. Respondent mailed a statutory notice of deficiency to petitioners concerning the years involved in the criminal trial and several prior…

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1. The Department of Justice's files relating to petitioner-husband were lost in 1973, but subsequently recovered. Held, the loss of such files does not constitute a violation of due process entitling petitioners to summary judgment or suppression of evidence. 2. Petitioner-husband was tried and acquitted of criminal tax fraud in May 1974. Respondent mailed a statutory notice of deficiency to petitioners concerning the years involved in the criminal trial and several prior years in March 1979. Petitioners argue that respondent's near 5-year delay in issuing a notice of deficiency after the…

1Opinion of the Court

W. Kenneth Riland and Gladys G. Riland, Petitioners v. Commissioner of Internal Revenue, Respondent

Riland v. Commissioner

Docket No. 6854-79

United States Tax Court

79 T.C. 185; 1982 U.S. Tax Ct. LEXIS 58; 79 T.C. No. 12;

August 2, 1982, Filed

1. The Department of Justice's files relating to petitioner-husband were lost in 1973, but subsequently recovered. Held, the loss of such files does not constitute a violation of due process entitling petitioners to summary judgment or suppression of evidence.

2. Petitioner-husband was tried and acquitted of criminal tax fraud in May 1974. Respondent mailed a…

2Cases cited68 opinions

  1. Miranda v. ArizonaSupreme Court of the United States · 1966
  2. Brady v. MarylandSupreme Court of the United States · 1963
  3. United States v. AgursSupreme Court of the United States · 1976
  4. Jackson v. DennoSupreme Court of the United States · 1964
  5. Fuentes v. ShevinSupreme Court of the United States · 1972

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