Legal Opinion

Chao v. Commissioner

United States Tax Court

Decided May 24, 1989No. Docket No. 2292-83Published

Over 2 years after entry of a decision sustaining a deficiency and awarding damages under sec. 6673, I.R.C. 1954, as amended, against them, petitioners moved to vacate the decision based on false representations to the Court by their former counsel. Held, the motion to vacate is denied where no different decision would be entered if the case were reopened.

1Opinion of the Court

Wen Y. Chao and Ching J. Chao, Petitioners v. Commissioner of Internal Revenue, Respondent

Chao v. Commissioner

Docket No. 2292-83

United States Tax Court

92 T.C. 1141; 1989 U.S. Tax Ct. LEXIS 70; 92 T.C. No. 73;

May 24, 1989. May 24, 1989, Filed

Petitioners' motion will be denied.

Over 2 years after entry of a decision sustaining a deficiency and awarding damages under sec. 6673, I.R.C. 1954, as amended, against them, petitioners moved to vacate the decision based on false representations to the Court by their former counsel. Held, the motion to vacate is denied where no different decision would be…

2Cases cited21 opinions

  1. Link v. Wabash RailroadSupreme Court of the United States · 1962
  2. Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  3. Josephine C. Toscano AKA Josephine C. Zelasko v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  4. Brooks v. CommissionerUnited States Tax Court · 1984
  5. Peter Billingsley v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989

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