Singleton v. Commissioner
United States Tax Court
After this case was set for trial and an evidentiary hearing scheduled on whether petitioner's constitutional rights guaranteed by the fourth and fifth amendments to the U.S. Constitution were violated, petitioner was indicted for income tax evasion for 1 of the 4 years pending before us.
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After this case was set for trial and an evidentiary hearing scheduled on whether petitioner's constitutional rights guaranteed by the fourth and fifth amendments to the U.S. Constitution were violated, petitioner was indicted for income tax evasion for 1 of the 4 years pending before us. Respondent moved for a protective order under Rule 103(a)(1), (2), and (4), Tax Court Rules of Practice and Procedure, to suspend all further proceedings pending the final disposition of the criminal indictment. Held, under the particular circumstances present here, respondent's motion is denied and further…
1Opinion of the Court
OPINION
The first issue is procedural. During the discovery process, after numerous hearings and after the case was at issue, respondent filed a motion for protective order requesting that we stay further proceedings pending the final disposition of a criminal indictment returned against petitioner the previous week. We denied respondent’s motion for protective order.
The petition in this case was filed on December 11, 1974. Because of the time required for disposition of issues raised by petitioner in motions filed after respondent filed his answer, the reply was not filed until September 2,…
2Cases cited59 opinions
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