Galanis v. Commissioner
United States Tax Court
P filed his 1977 and 1978 Federal income tax returns on Oct. 13, 1978, and Oct. 22, 1979, respectively. An involuntary petition under chapter 7 of title 11, U.S.C. (the Bankruptcy Code), naming P as debtor was filed on May 1, 1980. On Nov. 9, 1984, the Bankruptcy Court dismissed P's case. On Mar. 21, 1986, R issued a notice of deficiency for P's taxable years 1977 and 1978. A timely petition was filed.
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P filed his 1977 and 1978 Federal income tax returns on Oct. 13, 1978, and Oct. 22, 1979, respectively. An involuntary petition under chapter 7 of title 11, U.S.C. (the Bankruptcy Code), naming P as debtor was filed on May 1, 1980. On Nov. 9, 1984, the Bankruptcy Court dismissed P's case. On Mar. 21, 1986, R issued a notice of deficiency for P's taxable years 1977 and 1978. A timely petition was filed. Held, sec. 6503(i), I.R.C. 1954, added by the Bankruptcy Tax Act of 1980, provides that the period of limitations is suspended for the prohibition period (automatic stay under 11 U.S.C. sec.…
1Opinion of the Court
John Peter Galanis, Petitioner v. Commissioner of Internal Revenue, Respondent
Galanis v. Commissioner
Docket No. 21107-86
United States Tax Court
92 T.C. 34; 1989 U.S. Tax Ct. LEXIS 4; 92 T.C. No. 4;
January 17, 1989January 17, 1989, Filed
An order will be issued denying petitioner's motion for summary judgment.
P filed his 1977 and 1978 Federal income tax returns on Oct. 13, 1978, and Oct. 22, 1979, respectively. An involuntary petition under chapter 7 of title 11, U.S.C. (the Bankruptcy Code), naming P as debtor was filed on May 1, 1980. On Nov. 9, 1984, the Bankruptcy Court dismissed P's case.…
2Cases cited8 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Shiosaki v. CommissionerUnited States Tax Court · 1974
- Charlie Cox v. American Fidelity & Casualty Co., a Corporation and Underwriters at Lloyd's, LondonCourt of Appeals for the Ninth Circuit · 1957
- Giordano v. CommissionerUnited States Tax Court · 1975
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