Moody v. Commissioner
United States Tax Court
P, an individual, filed for bankruptcy under 11 U.S.C. ch. 13 (1982 edition as amended). The matter was subsequently converted to ch. 11. On Jan. 30, 1987, the trustee's second amended ch. 11 plan was confirmed by the District Court. Respondent later issued a notice of deficiency determining self-dealing excise tax liability for the years 1983 through 1987, and P timely filed his petition with this Court.
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P, an individual, filed for bankruptcy under 11 U.S.C. ch. 13 (1982 edition as amended). The matter was subsequently converted to ch. 11. On Jan. 30, 1987, the trustee's second amended ch. 11 plan was confirmed by the District Court. Respondent later issued a notice of deficiency determining self-dealing excise tax liability for the years 1983 through 1987, and P timely filed his petition with this Court. P now contends that this Court lacks jurisdiction because the automatic stay provisions of 11 U.S.C. sec. 362(a)(8) are still in effect as a result of a complaint filed in the bankruptcy…
1Opinion of the Court
Shearn Moody, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent
Moody v. Commissioner
Docket No. 2566-88
United States Tax Court
95 T.C. 655; 1990 U.S. Tax Ct. LEXIS 115; 95 T.C. No. 47;
December 26, 1990, Filed
P, an individual, filed for bankruptcy under 11 U.S.C. ch. 13 (1982 edition as amended). The matter was subsequently converted to ch. 11. On Jan. 30, 1987, the trustee's second amended ch. 11 plan was confirmed by the District Court. Respondent later issued a notice of deficiency determining self-dealing excise tax liability for the years 1983 through 1987, and P timely filed…
2Cases cited7 opinions
- Neilson v. CommissionerUnited States Tax Court · 1990
- Graham v. CommissionerUnited States Tax Court · 1980
- McClamma v. CommissionerUnited States Tax Court · 1981
- Olson v. CommissionerUnited States Tax Court · 1986
- Moody v. CommissionerUnited States Tax Court · 1990
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