McCoy v. Commissioner
United States Tax Court
Petitioners' persistent refusal to answer interrogatories or produce documents held, in the circumstances of this case, not only to constitute a default under Rule 123(a), but also to justify dismissal of the case and entry of judgment against them pursuant to Rules 104(c)(3) and (d), and 123(a) and (b).
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined the following income tax deficiencies and additions to tax against each of the petitioners, husband and wife:1
Additions to tax, I.R.C. 195U
Year Deficiency Sec. 6651(a) Sec. 6653(a) Sec. 665U
1973 $971 $171.28 $48.55 $19.68
1974 1,424 268.66 71.20 31.68
1975 2,648 338.17 132.40 44.82
1976 892 80.50 44.60 0
Petitioners filed a single petition challenging the foregoing determinations.
This case has been the subject of numerous motions, most of which were disposed of prior to May 18,1981, when the case was calendared for trial in Los Angeles. Petitioners…
2Cases cited6 opinions
- Zicarelli v. New Jersey State Commission of InvestigationSupreme Court of the United States · 1972
- Raymond J. Ryan and Helen Ryan v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1977
- Robert C. Eisele and Rita J. Eisele v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1978
- Burns v. CommissionerUnited States Tax Court · 1981
- Ryan v. CommissionerUnited States Tax Court · 1976
1 more not listed; retrieve them via the Exa API.
3Cited by245 opinions
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Norman E. McCoy and Mary Louise McCoy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Abrams v. CommissionerUnited States Tax Court · 1984
- Reiff v. CommissionerUnited States Tax Court · 1981
- Davis v. CommissionerUnited States Tax Court · 1983
240 more not listed; retrieve them via the Exa API.