Legal Opinion

Cochrane v. Commissioner

United States Tax Court

Decided August 7, 1996No. Docket No. 2002-95Published

P was ordered to file responses to R's requests for admission. P's subsequent responses to the requests for admission were evasive and incomplete and contained time-worn tax protester statements. R moved for sanctions, asking that the matter in the requested admissions be taken as established for purposes of this case.

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P was ordered to file responses to R's requests for admission. P's subsequent responses to the requests for admission were evasive and incomplete and contained time-worn tax protester statements. R moved for sanctions, asking that the matter in the requested admissions be taken as established for purposes of this case. Rule 90(c), Tax Court Rules of Practice and Procedure, generally requires that a party upon whom a request for admission is served specifically admit or deny the proposed admission. Rule 104(c), Tax Court Rules of Practice and Procedure, provides that the Court may sanction a…

1Opinion of the Court

JAMES LUTHER COCHRANE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cochrane v. Commissioner

Docket No. 2002-95.

United States Tax Court

107 T.C. 18; 1996 U.S. Tax Ct. LEXIS 32; 107 T.C. No. 2;

August 7, 1996, Filed

Decision will be entered for respondent.

P was ordered to file responses to R's requests for admission. P's subsequent responses to the requests for admission were evasive and incomplete and contained time-worn tax protester statements. R moved for sanctions, asking that the matter in the requested admissions be taken as established for purposes of this case.

Rule 90(c), Tax…

2Cases cited24 opinions

  1. Spies v. United StatesSupreme Court of the United States · 1943
  2. Rowlee v. CommissionerUnited States Tax Court · 1983
  3. Gajewski v. CommissionerUnited States Tax Court · 1976
  4. Beaver v. CommissionerUnited States Tax Court · 1970
  5. United States v. Ruth StudleyCourt of Appeals for the Ninth Circuit · 1986

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