Bishay v. Comm'r
United States Tax Court
P was the president, sole shareholder, and treasurer of Company (C). In 2002 C filed for bankruptcy and P was removed and replaced by a bankruptcy trustee.
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P was the president, sole shareholder, and treasurer of Company (C). In 2002 C filed for bankruptcy and P was removed and replaced by a bankruptcy trustee. C failed to pay over to R employment withholding taxes for its employees for two quarters in 2002. R sent P a Letter 1153 proposing to assess I.R.C. sec. 6672 penalties against P as a responsible person for C. P filed an appeal request and subsequently disputed the underlying liabilities in a conference with the Office of Appeals (Appeals) in November 2006. Appeals rejected P's appeal, determined that P was a responsible person for C, and…
1Opinion of the Court
BAHIG F. BISHAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bishay v. Comm'r
Docket No. 7537-14L.
United States Tax Court
T.C. Memo 2015-105; 2015 Tax Ct. Memo LEXIS 114; 109 T.C.M. (CCH) 1543;
June 4, 2015, Filed
An appropriate order and decision will be entered.
P was the president, sole shareholder, and treasurer of Company (C). In 2002 C filed for bankruptcy and P was removed and replaced by a bankruptcy trustee. C failed to pay over to R employment withholding taxes for its employees for two quarters in 2002. R sent P a Letter 1153 proposing to assess I.R.C. sec. 6672 penalties…
2Cases cited17 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Goza v. CommissionerUnited States Tax Court · 2000
- Slodov v. United StatesSupreme Court of the United States · 1978
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
12 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
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