Riland v. Commissioner
United States Tax Court
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
- Miranda v. ArizonaSupreme Court of the United States · 1966
- Brady v. MarylandSupreme Court of the United States · 1963
- United States v. AgursSupreme Court of the United States · 1976
- Jackson v. DennoSupreme Court of the United States · 1964
- Fuentes v. ShevinSupreme Court of the United States · 1972
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