Bell v. Commissioner
United States Tax Court
R obtained a copy of a criminal indictment, after it had been filed in open court, and used the information contained therein as a basis for the notices of deficiency issued to Ps. Ps contend that R's obtention and use of the indictment was a violation of rule 6(e), Federal Rules of Criminal Procedure (rule 6(e)), which shields from public disclosure matters occurring before the grand jury.
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R obtained a copy of a criminal indictment, after it had been filed in open court, and used the information contained therein as a basis for the notices of deficiency issued to Ps. Ps contend that R's obtention and use of the indictment was a violation of rule 6(e), Federal Rules of Criminal Procedure (rule 6(e)), which shields from public disclosure matters occurring before the grand jury. R's position is that the filed indictment is a public record and the procurement of a copy thereof and the subsequent use of the information contained therein is reasonable and proper. Neither Ps nor R…
1Opinion of the Court
Percy L. and Lois V. Bell, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Bell v. Commissioner
Docket Nos. 22733-84, 25769-84, 37219-84, 37220-84
United States Tax Court
90 T.C. 878; 1988 U.S. Tax Ct. LEXIS 60; 90 T.C. No. 59;
May 9, 1988; As amended May 19, 1988 May 9, 1988, Filed
R obtained a copy of a criminal indictment, after it had been filed in open court, and used the information contained therein as a basis for the notices of deficiency issued to Ps. Ps contend that R's obtention and use of the indictment was a violation of rule 6(e), Federal Rules of Criminal…
2Cases cited24 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme 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
- United States v. Richard CiambroneCourt of Appeals for the Second Circuit · 1979
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