Morris v. Commissioner
United States Tax Court
Petitioners seek to compel production of documents pursuant to Rule 72(b). Held, Rule 72(b) does not require any good-cause showing as a prerequisite to production of documents; held, further, production of the documents will be had; no objection was made to production on grounds of privilege or relevance, P.T. & L. Construction Co., 63 T.C. 404 (1974); held, further, no showing has been made that production is premature, and we will not postpone production without such…
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Petitioners seek to compel production of documents pursuant to Rule 72(b). Held, Rule 72(b) does not require any good-cause showing as a prerequisite to production of documents; held, further, production of the documents will be had; no objection was made to production on grounds of privilege or relevance, P.T. & L. Construction Co., 63 T.C. 404 (1974); held, further, no showing has been made that production is premature, and we will not postpone production without such showing. Andrew Piscatelli, 64 T.C. 424 (1975).
1Opinion of the Court
Forrester, Judge:
The interlocutory issue before us is whether to grant or deny petitioners’ Motion for Production of Documents Pursuant to Rule 72.1 The parties are in agreement as to all pertinent facts.
Petitioner Vincent Morris (Morris) was indicted, tried for, and acquitted of income tax evasion for each of the years involved in the instant case, 1966, 1967, and 1968. Respondent has determined deficiencies in income tax and additions to tax for fraud for each of those years.
In the course of investigating petitioners’ tax returns for the years involved, respondent’s agents interviewed…
2Cases cited7 opinions
- United States v. NoblesSupreme Court of the United States · 1975
- Alltmont v. United StatesCourt of Appeals for the Third Circuit · 1950
- Daniel J. McDougall Jr. v. Kenneth R. DunnCourt of Appeals for the Fourth Circuit · 1972
- P. T. & L. Constr. Co. v. CommissionerUnited States Tax Court · 1974
- Piscatelli v. CommissionerUnited States Tax Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Riland v. CommissionerUnited States Tax Court · 1982
- Llorente v. CommissionerUnited States Tax Court · 1980
- Llorente v. CommissionerUnited States Tax Court · 1980
- Morris v. CommissionerUnited States Tax Court · 1975
- Riland v. CommissionerUnited States Tax Court · 1982