Gould v. Comm'r
United States Tax Court
In 1984, P-H and several entities in which he owned interests filed voluntary petitions in ch. 11 bankruptcy. The bankruptcy court established a liquidating trust to which all assets of the bankruptcy estates were transferred. The liquidating trustee remitted payments to the Internal Revenue Service (IRS) in satisfaction of the income tax liabilities of the debtors, including P-H's bankruptcy estate, for tax years before those at issue herein.
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In 1984, P-H and several entities in which he owned interests filed voluntary petitions in ch. 11 bankruptcy. The bankruptcy court established a liquidating trust to which all assets of the bankruptcy estates were transferred. The liquidating trustee remitted payments to the Internal Revenue Service (IRS) in satisfaction of the income tax liabilities of the debtors, including P-H's bankruptcy estate, for tax years before those at issue herein. On Ps' individual joint 1995, amended 1995, and 1996-2002 Federal income tax returns, Ps reported net operating loss (NOL) deductions and estimated tax…
1Opinion of the Court
THEODORE B. GOULD AND ESTATE OF HELEN C. GOULD, DECEASED, THEODORE B. GOULD, EXECUTOR,1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gould v. Comm'r
Docket Nos. 5887-07L, 4592-08, 11606-10L.
United States Tax Court
139 T.C. 418; 2012 U.S. Tax Ct. LEXIS 43; 139 T.C. No. 17;
November 26, 2012, Filed
Gould v. Smith, 515 U.S. 1121, 115 S. Ct. 2275, 132 L. Ed. 2d 280, 1995 U.S. LEXIS 3806 (1995)
Decisions will be entered under Rule 155.
In 1984, P-H and several entities in which he owned interests filed voluntary petitions in ch. 11 bankruptcy. The bankruptcy court established a…
2Cases cited42 opinions
- Montana v. United StatesSupreme Court of the United States · 1979
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
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