Bugge v. USA

E. GRADY JOLLY, Circuit Judge:

Stephen Edward Bugge, a debtor in Chapter 7 bankruptcy proceedings and the former president of Coastal Crude Trucking, Inc. (“Coastal”), appeals from the district court’s affirmance of the bankruptcy court’s posttrial ruling that Bugge is liable for a $327,379.82 windfall profit tax penalty. He argues that the erroneous abatement of the IRS assessment — the assessment that is the basis for this tax penalty — should not have been reinstated because the statute of limitations had expired. Bugge also challenges the denial of his request for attorneys’ fees. We…