Hajecate v. Commissioner
United States Tax Court
Ps were targeted for grand jury investigation in the late 1970s. In 1979 and 1981, R obtained orders from a U.S. District Court pursuant to rule 6(e) of the Federal Rules of Criminal Procedure (rule 6(e)) permitting him to examine transcripts of testimony and materials relating to Ps' business operations obtained from several grand juries to determine whether any civil tax liabilities might arise therefrom.
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Ps were targeted for grand jury investigation in the late 1970s. In 1979 and 1981, R obtained orders from a U.S. District Court pursuant to rule 6(e) of the Federal Rules of Criminal Procedure (rule 6(e)) permitting him to examine transcripts of testimony and materials relating to Ps' business operations obtained from several grand juries to determine whether any civil tax liabilities might arise therefrom. R then lost track of the grand jury materials and did not discover their location until November 1986. R now has custody of the boxes of materials but neither R nor Ps know precisely what…
1Opinion of the Court
Thomas H. Hajecate and Dorothy A. Hajecate, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Hajecate v. Commissioner
Docket Nos. 498-81, 499-81, 500-81, 1250-82, 1251-82, 792-83, 793-83, 794-83, 795-83, 6809-83, 626-85
United States Tax Court
90 T.C. 280; 1988 U.S. Tax Ct. LEXIS 22; 90 T.C. No. 22;
February 17, 1988. February 17, 1988, Filed
Ps were targeted for grand jury investigation in the late 1970s. In 1979 and 1981, R obtained orders from a U.S. District Court pursuant to rule 6(e) of the Federal Rules of Criminal Procedure (rule 6(e)) permitting him to examine…
2Cases cited14 opinions
- Douglas Oil Co. of Cal. v. Petrol Stops NorthwestSupreme Court of the United States · 1979
- United States v. Sells Engineering, Inc.Supreme Court of the United States · 1983
- United States v. BaggotSupreme Court of the United States · 1983
- Kluger v. CommissionerUnited States Tax Court · 1984
- United States v. Interstate Dress Carriers, Inc.Court of Appeals for the Second Circuit · 1960
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