Franchi v. Commissioner
United States Tax Court
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.
Read the full summary
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
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Marshall v. CommissionerUnited States Tax Court · 1985
- Estate of SpearCourt of Appeals for the Third Circuit · 1994
- Coninck v. CommissionerUnited States Tax Court · 1993
- Estate of Spear v. CommissionerUnited States Tax Court · 1993