Brannen v. C.I.R

1 Citing brief

  1. USA v. Irizarry & McCall, P.C.

    RESPONSE TO ORDER TO SHOW CAUSE to Petition to Enforce Internal Revenue Summonses re

    Filed October 31, 2005

    Assoc. Series #115 v. C.I.R., No. 23263-89, 1994 WL 172749 (U.S. Tax Court May 9, 1994), involved admissibility at trial of other conduct of the same promoter. The government’s reliance on Brannen v. C.I.R., 78 T.C. 471 (1982), aff’d, 722 F.2d 695 (11th Cir 1984) (cited incorrectly as F.3d) is confounding, and the government’s failure to provide a pinpoint citation to the allegedly relevant part of the 52-page tax court opinion violates MSK Civil Practice Standard II.D.2. Case 1:05-cv-01818-MSK Document 5 Filed 10/31/05 USDC Colorado Page 13 of 14 115513 14 CONCLUSION The Court should reject the IRS’s attempt to compel the Law Firm to provide private third-party information that has no potential relevance to determining the liability of the taxpayer under investigation.