Legal Opinion

Franchi v. Commissioner

United States Tax Court

Decided January 26, 1995No. Docket No. 6131-92Unpublished

During the years at issue, P operated a business engaged in the preparation of income tax returns. P also received income from other activities. R determined that P had unreported income and that he had overstated certain deductions. Pursuant to Rule 90(a), Tax Court Rules of Practice and Procedure, R served upon P certain requests for admissions.

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During the years at issue, P operated a business engaged in the preparation of income tax returns. P also received income from other activities. R determined that P had unreported income and that he had overstated certain deductions. Pursuant to Rule 90(a), Tax Court Rules of Practice and Procedure, R served upon P certain requests for admissions. P did not respond to the requests; thus, under Rule 90(c), Tax Court Rules of Practice and Procedure, the facts contained within the admissions' requests are deemed admitted. Given the fact that all the facts necessary for a decision are deemed…

1Opinion of the Court

THOMAS C. FRANCHI, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Franchi v. Commissioner

Docket No. 6131-92

United States Tax Court

T.C. Memo 1995-37; 1995 Tax Ct. Memo LEXIS 38; 69 T.C.M. (CCH) 1754;

January 26, 1995, Filed

During the years at issue, P operated a business engaged in the preparation of income tax returns. P also received income from other activities. R determined that P had unreported income and that he had overstated certain deductions. Pursuant to Rule 90(a), Tax Court Rules of Practice and Procedure, R served upon P certain requests for admissions. P did not…

2Cases cited5 opinions

  1. Petzoldt v. CommissionerUnited States Tax Court · 1989
  2. Marshall v. CommissionerUnited States Tax Court · 1985
  3. Estate of SpearCourt of Appeals for the Third Circuit · 1994
  4. Coninck v. CommissionerUnited States Tax Court · 1993
  5. Estate of Spear v. CommissionerUnited States Tax Court · 1993

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