Estate of Woodard v. Commissioner
United States Tax Court
Rules 103, 161, Tax Court Rules of Practice and Procedure. -- Petitioners were granted a protective order under Rule 103 to relieve them from stipulating matters not material or relevant to the issues before the Court pursuant to our opinion in Estate of Russell G. Woodard, 64 T.C. 457 (1975). Respondent filed a motion under Rule 161 for reconsideration of our opinion in which he, for the first time, brought to the attention of the Court, the specific theory of his legal…
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Rules 103, 161, Tax Court Rules of Practice and Procedure. -- Petitioners were granted a protective order under Rule 103 to relieve them from stipulating matters not material or relevant to the issues before the Court pursuant to our opinion in Estate of Russell G. Woodard, 64 T.C. 457 (1975). Respondent filed a motion under Rule 161 for reconsideration of our opinion in which he, for the first time, brought to the attention of the Court, the specific theory of his legal position in these cases. Held: The motion for reconsideration is granted. The rationale of the first opinion is sound and…
1Opinion of the Court
Estate of Russell G. Woodard, Deceased, Annabelle M. Woodard, Charles B. Cumings and Genesee Merchants Bank & Trust Co., Co-Executors, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Woodard v. Commissioner
Docket Nos. 672-74, 673-74
United States Tax Court
64 T.C. 999; 1975 U.S. Tax Ct. LEXIS 76;
August 28, 1975, Filed
Rules 103, 161, Tax Court Rules of Practice and Procedure. -- Petitioners were granted a protective order under Rule 103 to relieve them from stipulating matters not material or relevant to the issues before the Court pursuant to our opinion in Estate…
2Cases cited2 opinions
- Estate of Woodard v. CommissionerUnited States Tax Court · 1975
- Estate of Woodard v. CommissionerUnited States Tax Court · 1975