Legal Opinion

Bussell v. Comm'r

United States Tax Court

Decided May 29, 2008No. 5766-04LPublished

R assessed income tax deficiencies, additions to tax, penalties, and interest against PW and her husband (H) for 1983, 1984, 1986, and 1987 (Ps' unpaid tax liabilities). In 1994 R filed notices of Federal tax lien in California and Utah with regard to Ps' unpaid tax liabilities. In early 1995 PW and H filed a bankruptcy petition under ch. 7 of the Bankruptcy Code. The bankruptcy court issued a discharge order in the bankruptcy case later that year.

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R assessed income tax deficiencies, additions to tax, penalties, and interest against PW and her husband (H) for 1983, 1984, 1986, and 1987 (Ps' unpaid tax liabilities). In 1994 R filed notices of Federal tax lien in California and Utah with regard to Ps' unpaid tax liabilities. In early 1995 PW and H filed a bankruptcy petition under ch. 7 of the Bankruptcy Code. The bankruptcy court issued a discharge order in the bankruptcy case later that year. In 2000 PW and H were indicted and charged with various violations associated with bankruptcy fraud. In February 2002 H died, and no verdict was…

1Opinion of the Court

LETANTIA BUSSELL AND ESTATE OF JOHN BUSSELL, DECEASED, LETANTIA BUSSELL, SURVIVING SPOUSE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bussell v. Comm'r

No. 5766-04L

United States Tax Court

130 T.C. 222; 2008 U.S. Tax Ct. LEXIS 13; 130 T.C. No. 13;

May 29, 2008, Filed

Bussell v. Comm'r, 262 Fed. Appx. 770, 2007 U.S. App. LEXIS 30216 (9th Cir., 2007)

R assessed income tax deficiencies, additions to tax, penalties, and interest against PW and her husband (H) for 1983, 1984, 1986, and 1987 (Ps' unpaid tax liabilities). In 1994 R filed notices of Federal tax lien in California and Utah…

2Cases cited48 opinions

  1. Grogan v. GarnerSupreme Court of the United States · 1991
  2. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  3. Montana v. United StatesSupreme Court of the United States · 1979
  4. Johnson v. Home State BankSupreme Court of the United States · 1991
  5. Cheek v. United StatesSupreme Court of the United States · 1991

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