Legal Opinion

Zaentz v. Commissioner

United States Tax Court

Decided December 17, 1979No. Docket Nos. 5609-74, 6078-75, 5411-76, 5370-77PublishedCited by 48 opinions

Rules 70 through 72 and 104, Tax Court Rules of Practice and Procedure. -- 1. Under Rules 71 and 72, R served upon P interrogatories and requests for production of documents.

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Rules 70 through 72 and 104, Tax Court Rules of Practice and Procedure. -- 1. Under Rules 71 and 72, R served upon P interrogatories and requests for production of documents. In his responses, P claimed to lack sufficient knowledge to answer some of the requests, and he objected to others on the grounds that the requested information and documents are irrelevant because they relate to transactions which are not at issue, that the requested information and documents deal with persons who are not parties to the case, and that the production of the requested information and documents would…

1Opinion of the Court

OPINION

Simpson, Judge:

Under Rule 104(b), Tax Court Rules of Practice and Procedure,1 petitioner Saul Zaentz and the Commissioner filed motions to compel discovery.2 The discovery requests at issue are: 153 paragraphs of interrogatories, and 22 paragraphs requesting the production of documents, submitted by the Commissioner; and 16 paragraphs, including interrogatories and requests for production of documents, submitted by the petitioner. These requests raise several questions which we shall deal with in order.

The Commissioner’s Requests

For the years at issue, Mr. Zaentz was a member of a…

2Cases cited15 opinions

  1. Hickman v. TaylorSupreme Court of the United States · 1947
  2. United States v. Procter & Gamble Co.Supreme Court of the United States · 1958
  3. Edward E. Colton and Lillian Kaltman v. United States of America, United States of America v. Edward E. ColtonCourt of Appeals for the Second Circuit · 1962
  4. Royal G. Bouschor v. United StatesCourt of Appeals for the Eighth Circuit · 1963
  5. P. T. & L. Constr. Co. v. CommissionerUnited States Tax Court · 1974

10 more not listed; retrieve them via the Exa API.

3Cited by48 opinions

  1. Dusha v. CommissionerUnited States Tax Court · 1984
  2. Rosenfeld v. CommissionerUnited States Tax Court · 1984
  3. Rutter v. CommissionerUnited States Tax Court · 1983
  4. Hartz Mountain Industries, Inc. v. CommissionerUnited States Tax Court · 1989
  5. Ames v. CommissionerUnited States Tax Court · 1999

43 more not listed; retrieve them via the Exa API.

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