Legal Opinion

Greenberg's Express, Inc. v. Commissioner

United States Tax Court

Decided June 18, 1974No. Docket Nos. 4006-72, 4036-72, 4038-72, 4055-72, 4220-72, 4245-72, 4269-72, 4286-72, 5538-72Published

1. Petitioners allege that respondent discriminatorily selected their income tax returns for a second examination because of their supposed family or business connections with persons purportedly involved in organized crime.

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1. Petitioners allege that respondent discriminatorily selected their income tax returns for a second examination because of their supposed family or business connections with persons purportedly involved in organized crime. Petitioners move under Rule 103(a) (10), Tax Court Rules of Practice and Procedure, for an order impounding various categories of documents in the custody, possession, or control of respondent and other Government agencies in order to enable them to obtain evidence to prove their allegations as to discriminatory selection. Held, an impounding order under Rule 103(a)(10)…

1Opinion of the Court

Greenberg's Express, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Greenberg's Express, Inc. v. Commissioner

Docket Nos. 4006-72, 4036-72, 4038-72, 4055-72, 4220-72, 4245-72, 4269-72, 4286-72, 5538-72

United States Tax Court

62 T.C. 324; 1974 U.S. Tax Ct. LEXIS 92; 62 T.C. No. 40;

June 18, 1974, Filed

1. Petitioners allege that respondent discriminatorily selected their income tax returns for a second examination because of their supposed family or business connections with persons purportedly involved in organized crime. Petitioners move under Rule 103(a) (10), Tax…

2Cases cited38 opinions

  1. Yick Wo v. HopkinsSupreme Court of the United States · 1886
  2. Shapiro v. ThompsonSupreme Court of the United States · 1969
  3. Oyler v. BolesSupreme Court of the United States · 1962
  4. United States v. PowellSupreme Court of the United States · 1964
  5. Helvering v. TaylorSupreme Court of the United States · 1935

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