Greenberg's Express, Inc. v. Commissioner

62 T.C. 324 (1974)

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Greenberg’s Express, Inc. v. Commissioner

United States Tax Court
62 T.C. 324 (1974)

Facts

Thomas Gambino and Joseph Gambino (plaintiffs) were sons of Carlo Gambino, a noted mob boss. The Internal Revenue Service (IRS) (defendant) issued notices of deficiency to both sons based on reinspections of the books of corporations with which the sons were involved. The sons challenged the notices in the United States Tax Court. The sons alleged that the IRS improperly targeted them because the government felt public pressure to appear to take organized crime seriously. The sons further alleged that the deficiencies the IRS determined were arbitrary and unreasonable, failing to adhere to established auditing procedures. The sons filed a motion for a protective order with the tax court seeking several forms of relief on the premise that the IRS unlawfully discriminated against them.

Rule of Law

Issue

Holding and Reasoning (Tannenwald, J.)

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