Penn-Field Industries, Inc. v. Commissioner
United States Tax Court
Rules 71 and 103, Tax Court Rules of Practice and Procedure. -- Petitioner filed a motion to compel respondent to answer interrogatories for statistical and other information concerning its allegation of invidious discrimination by respondent in the audit, settlement, and litigation of reasonable compensation cases.
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Rules 71 and 103, Tax Court Rules of Practice and Procedure. -- Petitioner filed a motion to compel respondent to answer interrogatories for statistical and other information concerning its allegation of invidious discrimination by respondent in the audit, settlement, and litigation of reasonable compensation cases. Respondent filed a motion for a protective order to relieve him of unnecessary and undue burden and expense in answering petitioner's interrogatories alleging that they are irrelevant to the issues before the Court. Held: Petitioner's motion to compel discovery of statistical and…
1Opinion of the Court
OPINION
Dawson, Judge:
On March 19, 1980, petitioner filed a “Motion For An Order Requiring Respondent To Answer Petitioner’s Interrogatories 1-248” under Rule 71, Tax Court Rules of Practice and Procedure. On April 28, 1980, respondent filed a “Motion For Protective Order” under Rule 103, Tax Court Rules of Practice and Procedure. A hearing was held on April 28, 1980, at Philadelphia where both parties made oral arguments, and the petitioner submitted a brief in response to respondent’s objections to its interrogatories.
Penn-Field Industries, Inc. (petitioner), is a corporation having its…
2Cases cited17 opinions
- Bolling v. SharpeSupreme Court of the United States · 1954
- Oyler v. BolesSupreme Court of the United States · 1962
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- United States v. Pablo BerriosCourt of Appeals for the Second Circuit · 1974
- United States v. John Paul MalinowskiCourt of Appeals for the Third Circuit · 1973
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- Slovacek v. United StatesUnited States Court of Federal Claims · 1998
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