Branerton Corp. v. Commissioner

61 T.C. 691 (1974)

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Branerton Corp. v. Commissioner

United States Tax Court
61 T.C. 691 (1974)

Facts

The Internal Revenue Service (IRS) (defendant) issued notices of deficiency to several taxpayers (plaintiffs). The taxpayers filed petitions in the United States Tax Court challenging the notices. During discovery, the taxpayers’ lawyers served extensive written interrogatories on the IRS. The taxpayers had not attempted to schedule informal conferences or discussions with IRS agents before serving the interrogatories. The IRS filed a motion for a protective order stating that it did not need to answer the interrogatories.

Rule of Law

Issue

Holding and Reasoning (Dawson, J.)

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