Branerton Corp. v. Commissioner
United States Tax Court
Rule 72, Tax Court Rules of Practice and Procedure. -- Petitioner filed a motion for an order requiring respondent to produce two revenue agents' reports, two district conferee reports, an appellate conferee's report, two conference memoranda, and each and every other document pertaining to the audit of petitioner's Federal income tax returns for taxable years ended Mar. 31, 1967, 1968, and 1969. Held: 1. Respondent's objection to the production of the two district conferee…
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Rule 72, Tax Court Rules of Practice and Procedure. -- Petitioner filed a motion for an order requiring respondent to produce two revenue agents' reports, two district conferee reports, an appellate conferee's report, two conference memoranda, and each and every other document pertaining to the audit of petitioner's Federal income tax returns for taxable years ended Mar. 31, 1967, 1968, and 1969. Held: 1. Respondent's objection to the production of the two district conferee reports, the appellate conferee reports, two conference memoranda, and certain other documents pertaining to the audit…
1Opinion of the Court
Dawson, Chief Judge:
This matter is before the Court on petitioner’s motion to compel production of documents pursuant to Rule 72, Tax Court Rules of Practice and Procedure. Oral arguments on the motion, together with the testimony of three witnesses, were heard on February 5, 1975. Written memoranda of law were filed by both parties. The documents in question were submitted to the Court for its in camera inspection.
The history of this case may be summarized as follows: A statutory notice of deficiency was mailed to petitioner on April 20, 1973. The adjustments therein related to (1) additions…
2Cases cited20 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- National Labor Relations Board v. Sears, Roebuck & Co.Supreme Court of the United States · 1975
- Environmental Protection Agency v. MinkSupreme Court of the United States · 1973
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Kaiser Aluminum & Chemical Corp. v. United StatesUnited States Court of Claims · 1958
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3Cited by44 opinions
- In re Folding Carton Antitrust LitigationDistrict Court, N.D. Illinois · 1977
- Rosenfeld v. CommissionerUnited States Tax Court · 1984
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- Ogiony v. CommissionerCourt of Appeals for the Second Circuit · 1980
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