Pleier v. Commissioner
United States Tax Court
92 T.C. 499 (1989)
- Written by Steven Pacht, JD
Facts
Carl Plier (plaintiff) filed a petition against the commissioner (defendant) of the Internal Revenue Service (IRS) in the United States Tax Court. The commissioner propounded interrogatories to Plier. However, the interrogatories did not pose any questions. Rather, the interrogatories asked Plier to fill out blank IRS Form 1040s regarding each item that Plier contended was relevant or potentially relevant to the determination of Plier’s tax liability, to provide other information on the Form 1040s, and to describe on a separate form all specified facts know by other persons and provide contact information for such persons. Plier objected to the interrogatories and moved for a protective order pursuant to Rule 103 of the Rules of Practice and Procedure of the United States Tax Court (Tax Court Rules) on the ground that the interrogatories did not request answers to any questions. The commissioner moved to compel Plier to respond to the interrogatories.
Rule of Law
Issue
Holding and Reasoning (Parr, J.)
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