Legal Opinion

Miller v. Internal Revenue Service (In Re Miller)

United States Bankruptcy Appellate Panel for the Ninth Circuit

Decided December 1, 1994No. BAP No. EC-93-2330-RVRo. Bankruptcy No. 93-20639-A-13PublishedCited by 12 opinions

1Opinion of the Court

OPINION

RUSSELL, Bankruptcy Judge:

The debtor objected to the Internal Revenue Service (“IRS”) claim on the grounds that the statute of limitations had expired and that consents executed between the tax matter partner and the IRS were invalid. In addition, the debtor attempted to set aside a closing agreement based on an alleged misrepresentation by the IRS. The bankruptcy court overruled the objection to the IRS claim. The debtor appeals. We AFFIRM.

I.FACTS

The facts are largely undisputed. The debtor/appellant, Guy Miller (“Miller”) filed a Chapter 13 petition. The appellee, IRS, submitted a…

2Cases cited20 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  3. Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
  4. Zaentz v. CommissionerUnited States Tax Court · 1988
  5. Heritage Hotel Ltd. Partnership I v. Valley Bank of Nevada (In Re Heritage Hotel Partnership I)United States Bankruptcy Appellate Panel for the Ninth Circuit · 1993

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3Cited by12 opinions

  1. S & O Liquidating Partnership v. Commissioner of Internal Revenue, Appeals of David Beach, Robert M. Berliner, Jay I. BorowCourt of Appeals for the Seventh Circuit · 2002
  2. In Re Marianne Hopkins, Debtor. Marianne Hopkins v. United StatesCourt of Appeals for the Ninth Circuit · 1998
  3. Dees v. United States (In Re Dees)United States Bankruptcy Court, N.D. Florida · 2007
  4. Comptroller of the Treasury v. Colonial Farm Credit, ACACourt of Special Appeals of Maryland · 2007
  5. In Re KleeUnited States Bankruptcy Court, D. Oregon · 1997

7 more not listed; retrieve them via the Exa API.

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