Legal Opinion

Schneider Interests, L.P. v. Comm'r

United States Tax Court

Decided September 30, 2002No. 200-02Published

Four months after the instant case was docketed, R sent P a so- called Branerton letter consisting of 68 pages of questions and requests for documents. Thirty-five days later, R instituted formal discovery by serving upon P 77 pages of interrogatories and 78 pages of requests for production of documents.

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Four months after the instant case was docketed, R sent P a so- called Branerton letter consisting of 68 pages of questions and requests for documents. Thirty-five days later, R instituted formal discovery by serving upon P 77 pages of interrogatories and 78 pages of requests for production of documents. R rejected P's suggestion that compliance with formal discovery be postponed until the parties held a conference, stating that the instant case is "a good candidate for designation for litigation under IRM 35.3.14." P then filed a Motion for Protective Order seeking to stay compliance with…

1Opinion of the Court

SCHNEIDER INTERESTS, L.P., RUSS SCHNEIDER FARMS, L.L.C., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Schneider Interests, L.P. v. Comm'r

No. 200-02

United States Tax Court

119 T.C. 151; 2002 U.S. Tax Ct. LEXIS 45; 119 T.C. No. 8;

September 30, 2002, Filed

An appropriate order will be issued.

Four months after the instant case was docketed, R sent P a so-

called Branerton letter consisting of 68 pages of

questions and requests for documents. Thirty-five days later, R

instituted formal discovery by serving upon P 77 pages of

interrogatories and 78 pages of requests for…

2Cases cited5 opinions

  1. Branerton Corp. v. CommissionerUnited States Tax Court · 1974
  2. Odend'hal v. CommissionerUnited States Tax Court · 1980
  3. International Air Conditioning Corp. v. CommissionerUnited States Tax Court · 1976
  4. Ash v. CommissionerUnited States Tax Court · 1991
  5. Schneider Interests, L.P. v. Comm'rUnited States Tax Court · 2002

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