Sampson v. Commissioner
United States Tax Court
After the parties herein were at issue, but before trial, T, a third party to whom no statutory notice had been issued, moved to enter the case as a party petitioner. The motion was denied without explanation, and T appealed to the Court of Appeals, which vacated the order and remanded the case for this Court to state the basis of the denial. Upon remand, Held, that T, not having been issued a notice of deficiency, may not enter the instant case as a party petitioner.
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After the parties herein were at issue, but before trial, T, a third party to whom no statutory notice had been issued, moved to enter the case as a party petitioner. The motion was denied without explanation, and T appealed to the Court of Appeals, which vacated the order and remanded the case for this Court to state the basis of the denial. Upon remand, Held, that T, not having been issued a notice of deficiency, may not enter the instant case as a party petitioner. Held, further, that in appropriate circumstances, such a third party may be allowed to enter the case as an intervenor, in the…
1Opinion of the Court
William C. Sampson and Lucille A. Sampson, Petitioners v. Commissioner of Internal Revenue, Respondent
Sampson v. Commissioner
Docket No. 3394-81
United States Tax Court
81 T.C. 614; 1983 U.S. Tax Ct. LEXIS 33; 81 T.C. No. 33;
September 22, 1983, Filed
After the parties herein were at issue, but before trial, T, a third party to whom no statutory notice had been issued, moved to enter the case as a party petitioner. The motion was denied without explanation, and T appealed to the Court of Appeals, which vacated the order and remanded the case for this Court to state the basis of the denial. Upon…
2Cases cited23 opinions
- Northern Pipeline Construction Co. v. Marathon Pipe Line Co.Supreme Court of the United States · 1982
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. TowerSupreme Court of the United States · 1946
- Burnet v. HarmelSupreme Court of the United States · 1932
- Poe v. SeabornSupreme Court of the United States · 1930
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