Legal Opinion

Graham v. Commissioner

United States Tax Court

Decided December 16, 1980No. Docket No. 7670-78Published

An income tax audit for prebankruptcy years (1972 and 1973) began and a 30-day letter was issued prior to the filing of a voluntary bankruptcy petition in a no-asset estate. Respondent did not make an immediate assessment pursuant to sec. 6871(a), I.R.C. 1954, or file a proof of claim with the bankruptcy court, and no application was filed in the bankruptcy proceeding to determine the dischargeability of petitioner's tax liability for the prebankruptcy years.

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An income tax audit for prebankruptcy years (1972 and 1973) began and a 30-day letter was issued prior to the filing of a voluntary bankruptcy petition in a no-asset estate. Respondent did not make an immediate assessment pursuant to sec. 6871(a), I.R.C. 1954, or file a proof of claim with the bankruptcy court, and no application was filed in the bankruptcy proceeding to determine the dischargeability of petitioner's tax liability for the prebankruptcy years. The bankrupt was discharged, and the proceeding was closed. Shortly thereafter, respondent sent petitioner a notice of deficiency for…

1Opinion of the Court

Ralph B. Graham, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent

Graham v. Commissioner

Docket No. 7670-78

United States Tax Court

75 T.C. 389; 1980 U.S. Tax Ct. LEXIS 14; 7 Bankr. Ct. Dec. 16;

December 16, 1980, Filed

Decision will be entered for the respondent.

An income tax audit for prebankruptcy years (1972 and 1973) began and a 30-day letter was issued prior to the filing of a voluntary bankruptcy petition in a no-asset estate. Respondent did not make an immediate assessment pursuant to sec. 6871(a), I.R.C. 1954, or file a proof of claim with the bankruptcy court, and no…

2Cases cited25 opinions

  1. In the Matter of Harry Stanley Bostwick and Steva Maxine Bostwick, Bankrupts. Harry Stanley Bostwick v. United StatesCourt of Appeals for the Eighth Circuit · 1975
  2. Burns, Stix Friedman & Co. v. CommissionerUnited States Tax Court · 1971
  3. Swanson v. CommissionerUnited States Tax Court · 1976
  4. In the Matter of John West Gwilliam, Bankrupt. John West Gwilliam v. United StatesCourt of Appeals for the Ninth Circuit · 1975
  5. Continental Equities, Inc., Cross-Appellant v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977

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