Legal Opinion

Sharpe v. Commissioner

United States Tax Court

Decided October 18, 1977No. Docket No. 10490-76Published

On Apr. 26, 1976, petitioner filed a voluntary bankruptcy petition in the District Court. The next day he was adjudicated a bankrupt and a receiver was appointed.

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On Apr. 26, 1976, petitioner filed a voluntary bankruptcy petition in the District Court. The next day he was adjudicated a bankrupt and a receiver was appointed. The first meeting of creditors was held on June 7, 1976, and the last date for filing proofs of claims was fixed at Dec. 7, 1976. Respondent mailed petitioner a notice of deficiency on Aug. 28, 1976, covering income tax deficiencies for the years 1966 through 1969 and an addition to tax under sec. 6651 (a), I.R.C. 1954, for 1969. On Nov. 22, 1976, respondent filed a proof of claim in the bankruptcy proceeding for the income tax…

1Opinion of the Court

Charles N. Sharpe, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent

Sharpe v. Commissioner

Docket No. 10490-76

United States Tax Court

69 T.C. 19; 1977 U.S. Tax Ct. LEXIS 39;

October 18, 1977, Filed

On Apr. 26, 1976, petitioner filed a voluntary bankruptcy petition in the District Court. The next day he was adjudicated a bankrupt and a receiver was appointed. The first meeting of creditors was held on June 7, 1976, and the last date for filing proofs of claims was fixed at Dec. 7, 1976. Respondent mailed petitioner a notice of deficiency on Aug. 28, 1976, covering income tax…

Also in this document: Concurrence; Dissent.

2Cases cited22 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. Simonson v. GranquistSupreme Court of the United States · 1962
  3. In the Matter of Lloyd James Durensky, Bankrupt. United States of America v. Lloyd James DurenskyCourt of Appeals for the Fifth Circuit · 1975
  4. In the Matter of John West Gwilliam, Bankrupt. John West Gwilliam v. United StatesCourt of Appeals for the Ninth Circuit · 1975
  5. Menick v. HoffmanCourt of Appeals for the Ninth Circuit · 1953

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