Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue Service

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a taxpayer's misunderstanding of the Tax Court's Rules is insufficient to overcome the doctrine of finality
• defining fraud upon the court as \an unconscionable plan or scheme which is designed to improperly influence the court in its decision\ or a fraudulent act that \prevents the opposing party from fully and fairly presenting his case\
• \fraud on the court may 9 occur when the acts of a party prevent his adversary from fully 10 and fairly presenting his case or defense\
• \fraud on the court may 9 occur when the acts of a party prevent his adversary from fully 10 and fairly presenting his case or defense\
• fraud upon the court involves unconscionable plan or scheme to influence the court improperly
• “We will reverse for abuse of discretion only if we have a definite and firm conviction that the Tax Court committed a clear error of judgment in the conclusion it reached.”

Source: CourtListener parenthetical corpus (CC0).