Grandbouche v. Commissioner
United States Tax Court
In connection with P's 1987 income tax liability, R subpoenaed various documents from a bank (the bank) where P maintained an account. A number of the documents subpoenaed contain information relating to an alleged tax protester organization (the organization) and its individual members (the members). The organization, as an "other affected person", filed a motion and supplemental motion for a protective order under Rule 103(a)(7), Tax Court Rules of Practice and Procedure.
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In connection with P's 1987 income tax liability, R subpoenaed various documents from a bank (the bank) where P maintained an account. A number of the documents subpoenaed contain information relating to an alleged tax protester organization (the organization) and its individual members (the members). The organization, as an "other affected person", filed a motion and supplemental motion for a protective order under Rule 103(a)(7), Tax Court Rules of Practice and Procedure. In support of its motions, the organization alleges that the release of any information which identifies its members…
1Opinion of the Court
OPINION
Jacobs, Judge:
Respondent determined a deficiency in petitioner’s 1987 Federal income tax as follows:
Additions to tax
Deficiency Sec* 6653(a)(1)(A) Sec, 6653(a)(1)(B) Sec. 6654 Sec, 6661
$238,606 $11,930 1 $12,881 $59,652
All section references are to the Internal Revenue Code in effect for 1987, and unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure.
The matters presently before the Court are a motion under Rule 103(a)(7) for a protective order filed by the National Commodity and Barter Association/National Commodity Exchange (ncba/nce;…
2Cases cited38 opinions
- Buckley v. ValeoSupreme Court of the United States · 1976
- National Ass'n for the Advancement of Colored People v. Alabama Ex Rel. PattersonSupreme Court of the United States · 1958
- Shelton v. TuckerSupreme Court of the United States · 1960
- Eastland v. United States Servicemen's FundSupreme Court of the United States · 1975
- Heat & Control, Inc. v. Hester Industries, Inc.Court of Appeals for the Federal Circuit · 1986
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3Cited by7 opinions
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- National Commodity & Barter Ass'n/National Commodity Exchange v. United StatesDistrict Court, D. Colorado · 1993
- Church of World Peace v. CommissionerUnited States Tax Court · 1994
- AmazonUnited States Tax Court · 2014
- Grandbouche v. CommissionerUnited States Tax Court · 1992
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