Bussell v. Comm'r
United States Tax Court
R assessed income tax deficiencies, additions to tax, penalties, and interest against PW and her husband (H) for 1983, 1984, 1986, and 1987 (Ps' unpaid tax liabilities). In 1994 R filed notices of Federal tax lien in California and Utah with regard to Ps' unpaid tax liabilities. In early 1995 PW and H filed a bankruptcy petition under ch. 7 of the Bankruptcy Code. The bankruptcy court issued a discharge order in the bankruptcy case later that year.
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R assessed income tax deficiencies, additions to tax, penalties, and interest against PW and her husband (H) for 1983, 1984, 1986, and 1987 (Ps' unpaid tax liabilities). In 1994 R filed notices of Federal tax lien in California and Utah with regard to Ps' unpaid tax liabilities. In early 1995 PW and H filed a bankruptcy petition under ch. 7 of the Bankruptcy Code. The bankruptcy court issued a discharge order in the bankruptcy case later that year. In 2000 PW and H were indicted and charged with various violations associated with bankruptcy fraud. In February 2002 H died, and no verdict was…
1Opinion of the Court
Marvel, Judge:
Petitioners1 invoked the Court’s jurisdiction pursuant to section 6330(d)2 to review respondent’s determination that it was appropriate to collect petitioners’ unpaid tax liabilities for 1983, 1984, 1986, and 1987 (sometimes referred to as the years in issue) by serving jeopardy levies. As explained in detail below, we shall sustain respondent’s determination.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the stipulated facts into our findings by this reference. Petitioner Letantia Bussell (petitioner) resided in California when the petition was filed.
Peti…
2Cases cited47 opinions
- Grogan v. GarnerSupreme Court of the United States · 1991
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Johnson v. Home State BankSupreme Court of the United States · 1991
- Cheek v. United StatesSupreme Court of the United States · 1991
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3Cited by11 opinions
- Everett Assocs. v. Comm'rUnited States Tax Court · 2012
- Prince v. Comm'rUnited States Tax Court · 2009
- Benjamin Jeffery Ashmore v. CommissionerUnited States Tax Court · 2017
- Bibby v. Comm'rUnited States Tax Court · 2013
- Bussell v. Comm'rUnited States Tax Court · 2008
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