Graham v. Commissioner
United States Tax Court
R determined deficiencies and fraud additions against Ps based upon documents, testimony, and other information secured by R's agents from grand jury proceedings.
Read the full summary
R determined deficiencies and fraud additions against Ps based upon documents, testimony, and other information secured by R's agents from grand jury proceedings. These grand jury materials were obtained under Federal District Court orders under rule 6(e), Federal Rules of Criminal Procedure, which were issued by the District Courts in 1971 and 1973 before the Supreme Court's decisions in United States v. Sells Engineering, Inc., 463 U.S. 300 (1983), and United States v. Baggot, 463 U.S. (1983). Held, assuming R's use of the grand jury materials was improper, such use does not invalidate the…
1Opinion of the Court
Thomas A. Graham and Elizabeth Graham, Petitioners v. Commissioner of Internal Revenue, Respondent; Meridian Engineering, Inc. of Pennsylvania, Petitioner v. Commissioner of Internal Revenue, Respondent
Graham v. Commissioner
Docket Nos. 7603-80, 7604-80
United States Tax Court
82 T.C. 299; 1984 U.S. Tax Ct. LEXIS 104; 82 T.C. No. 25;
February 27, 1984, Filed
Decisions will be entered for the respondent.
R determined deficiencies and fraud additions against Ps based upon documents, testimony, and other information secured by R's agents from grand jury proceedings. These grand jury materials were…
Also in this document: Concurrence · Wilbur; Concurrence · Nims; Concurrence · Whitaker; Concurrence · Cohen.
2Cases cited32 opinions
- Stone v. PowellSupreme Court of the United States · 1976
- United States v. CalandraSupreme Court of the United States · 1974
- Elkins v. United StatesSupreme Court of the United States · 1960
- United States v. JanisSupreme Court of the United States · 1976
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
27 more not listed; retrieve them via the Exa API.