Industrial Electric Sales & Service, Inc. v. Commissioner
United States Tax Court
Rules 70 and 72, Tax Court Rules of Practice and Procedure. -- During the course of the investigation of P's tax liability, the Commissioner's agents interviewed several witnesses and took statements from some of them. P moved for the production of such statements and any memorandums or summaries of the interviews. The Commissioner objected, claiming such material may be used for impeachment purposes.
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Rules 70 and 72, Tax Court Rules of Practice and Procedure. -- During the course of the investigation of P's tax liability, the Commissioner's agents interviewed several witnesses and took statements from some of them. P moved for the production of such statements and any memorandums or summaries of the interviews. The Commissioner objected, claiming such material may be used for impeachment purposes. Held, the documents must be produced, but the production is postponed until P responds to the Commissioner's requested admissions.
1Opinion of the Court
OPINION
Simpson, Judge:
In this consolidated case, the Commissioner has objected to the petitioners’ motion pursuant to Rule 72, Tax Court Rules of Practice and Procedure,1 for the production of statements and memorandums of interviews with 16 people questioned by the Commissioner’s agents.
Petitioner, Industrial Electric Sales & Service, Inc. (Industrial), is a corporation engaged in the business of repairing and installing electrical motors. During the years in issue, Mr. Hale was Industrial’s president and principal owner. The major issue in this consolidated case is whether Industrial had…
2Cases cited6 opinions
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- P. T. & L. Constr. Co. v. CommissionerUnited States Tax Court · 1974
- Hikel v. AbousyDistrict Court, D. Maryland · 1966
- Dvorak v. CommissionerUnited States Tax Court · 1975
- Stone v. Marine Transport Lines, Inc.District Court, D. Maryland · 1959
1 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Riland v. CommissionerUnited States Tax Court · 1982
- Zaentz v. CommissionerUnited States Tax Court · 1979
- Rutter v. CommissionerUnited States Tax Court · 1983
- Barger v. CommissionerUnited States Tax Court · 1976
- Barger v. CommissionerUnited States Tax Court · 1976
6 more not listed; retrieve them via the Exa API.