Hambrick v. Comm'r
United States Tax Court
Ps filed for a ch. 11 reorganization in bankruptcy. R filed a proof of claim setting forth income tax liabilities for 3 taxable years. The bankruptcy court ordered Ps to file returns. After the returns were filed, R made amendments to his proof of claim. Ps did not object to the tax liabilities set forth in R's claim, and the bankruptcy court confirmed the plan of reorganization without deciding the merits of Ps' tax liabilities.
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Ps filed for a ch. 11 reorganization in bankruptcy. R filed a proof of claim setting forth income tax liabilities for 3 taxable years. The bankruptcy court ordered Ps to file returns. After the returns were filed, R made amendments to his proof of claim. Ps did not object to the tax liabilities set forth in R's claim, and the bankruptcy court confirmed the plan of reorganization without deciding the merits of Ps' tax liabilities. Following the bankruptcy court's confirmation of the plan, R determined income tax deficiencies and additions to tax for the same 3 taxable years. The deficiencies,…
1Opinion of the Court
MICHAEL K. AND JUNE C. HAMBRICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hambrick v. Comm'r
No. 9260-00
United States Tax Court
118 T.C. 348; 2002 U.S. Tax Ct. LEXIS 21; 118 T.C. No. 20;
April 22, 2002, Filed
Respondent not estopped from determining deficiencies for the same tax years already claimed in petitioners' bankruptcy reorganization.
Ps filed for a ch. 11 reorganization in bankruptcy. R filed
a proof of claim setting forth income tax liabilities for 3
taxable years. The bankruptcy court ordered Ps to file returns.
After the returns were filed, R made amendments to his proof…
2Cases cited17 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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