Roberts v. United States Ex Rel. Internal Revenue Service (In Re Roberts)

OPINION

WILLIAM V. ALTENBERGER, Bankruptcy Judge.

The Debtor invested as a limited partner in a tax shelter with Philatelic Leasing, Ltd., a limited partnership (“PHILATELIC”). After he filed his personal income tax returns for the years 1979 through 1984, the Internal Revenue Service (“IRS”) audited PHILATELIC which resulted in a Tax Court decision in U.S. v. Philatelic Leasing, Ltd,., 794 F.2d 781, 86-2 USTC, para. 9509 (2d Cir.1986), where the tax court affirmed the granting of an injunction prohibiting the sale of abusive or fraudulent tax shelters. The IRS and the Debtor then stipulated…