Legal Opinion

Pitts v. United States (In re Pitts)

District Court, C.D. California

Decided August 12, 2014No. 5:13-v-02099-ODW; Bankruptcy No. 6:12-cv-15291-SC; Adversary No. 6:12-ap-01191-SCPublishedCited by 2 opinions

1Opinion of the Court

ORDER AFFIRMING BANKRUPTCY COURT’S DECISION

OTIS D. WRIGHT, II, District Judge.

I. INTRODUCTION

When a general partnership fails to pay required federal taxes, how can the Internal Revenue Service (“IRS”) recover those obligations from general partners? The United States Supreme Court resolved many issues relating to general-partner liability for unpaid partnership tax debts in United States v. Galletti, 541 U.S. 114, 124 S.Ct. 1548, 158 L.Ed.2d 279 (2004). But the Court also left many issues unresolved, including whether the IRS could employ administrative-collection procedures against the…

2Cases cited16 opinions

  1. Mathews v. EldridgeSupreme Court of the United States · 1976
  2. Joint Anti-Fascist Refugee Committee v. McGrathSupreme Court of the United States · 1951
  3. United States v. SummerlinSupreme Court of the United States · 1940
  4. Guaranty Trust Co. v. United StatesSupreme Court of the United States · 1938
  5. Commissioner v. SternSupreme Court of the United States · 1958

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3Cited by2 opinions

  1. United States v. Jung Joo ParkDistrict Court, E.D. Illinois · 2019
  2. United States v. ParkDistrict Court, N.D. Illinois · 2019

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