Thursday, May 13, 2021

Musings on Routine Petition to Quash Summons Denial (5/13/21)

In Sturman v. United States (N.D. Cal. Case No. 20-cv-07787-JSC Dkt. Entry 26 Order dated 5/12/21), CL here and TN pdf here, the Court sustained the summons.  This is fairly routine, so I will not pursue the details in this blog entry.

What caught my eye is that the Petitioner on the Petition to Quash Summons, CL here, is David A. Sturman.  That name rung a bell.  A prominent tax crimes case is United States v. Sturman, 951 F.2d 1466, 1476 (6th Cir. 1991), here, which I have discussed in several blogs (see here).  I could not quickly figure out whether it is the same David A. Sturman.  If anybody knows, please comment or email me at

Side note:  Tax Analysts / Tax Notes, under sponsorship of Deloitte, provides original tax documents including court opinions.  Deloitte and Tax Analysts Open Tax Analysts Library to Public Without Subscription ( Federal Tax Crimes Blog 1/11/21), here.  The court opinions are provided in OCR text format and in pdf format (Tax Court pdf with Tax Notes stamp).  For example, in this Sturman case, the OCR is here and the pdf is here.  The OCR seems to have everything except the case number which is on the first page of the pdf copy.  That's a bit weird.  Similarly, I have noted that, when TN offers a Tax Court case, the OCR does not have the citation (TC or TCM but the pdf does).  See, for example, the OCR here and the pdf here for a recent case, BRC Operating Co. LLC v. Commissioner, T.C. Memo. 2021-59.  For the actual citation, you have to link to the TN pdf which has the TCM citation as the first item on the Court's TCM Slip Op. (with TN stamp)  That too is weird.  I am not sure what Tax Notes' and Deloitte's respective strategies are for excluding that key information from the OCR copy, for it seems to be a deliberate omission that a robot OCR routine would not leave out.

Other note:  I check the links when I post and they work OK, but I have noticed that some of the TN links for the pdf will not work after a time.  I am not sure why that is the case.  For future posts, I will stick to Court or CourtListener links.  

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