Legal Opinion

Michael v. Severo and Georgina C. Severo v. Commissioner

United States Tax Court

Decided November 15, 2007No. 6346-06LUnknown

1Opinion of the Court

129 T.C. No. 17

UNITED STATES TAX COURT MICHAEL V. SEVERO AND GEORGINA C. SEVERO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6346-06L. Filed November 15, 2007. With the late filing of their 1990 joint Federal income tax return, petitioners failed to pay most of the $63,499 taxes reported due. In 1994, petitioners filed a bankruptcy petition. In 1998, petitioners received a bankruptcy discharge order. In 2004, respondent levied against petitioners’ $196 California income tax refund and notified petitioners of their appeal rights with regard thereto. Petitioners did…

2Cases cited17 opinions

  1. Young v. United StatesSupreme Court of the United States · 2002
  2. Everett v. JudsonSupreme Court of the United States · 1913
  3. Keith Orum and Cherie Orum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2005
  4. Orum v. Comm'rUnited States Tax Court · 2004
  5. KENNEDY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001

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