Legal Opinion
Cunningham v. United States (In Re Freytag)
District Court, N.D. Texas
Decided August 22, 1994No. Bankruptcy No. 390-30082-HCA-7. Civ. A. No. 3:93-CV-2094-GPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM ORDER
FISH, District Judge.
Before the court is the appeal of debtor Sharon Freytag (“Ms. Freytag”) from an order of the bankruptcy court determining that she is not entitled to relief as an innocent spouse from the claims of the Internal Revenue Service (“IRS”). For the reasons stated below, the order of the bankruptcy court is affirmed.
I. BACKGROUND
Sharon and Thomas Freytag deducted substantial losses on their joint federal income tax returns for the years 1978-1982. Bankruptcy Court’s Memorandum Opinion, August 11,1993 (“Bankruptcy Opinion”) at 3; Brief of Appellants (“Appellants’…
2Cases cited22 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Corning Glass Works v. BrennanSupreme Court of the United States · 1974
- In the Matter of Multiponics, Incorporated, Bankrupt. MacHinery Rental, Inc. And Carl Biehl v. William W. Herpel, TrusteeCourt of Appeals for the Fifth Circuit · 1980
- Freytag v. CommissionerUnited States Tax Court · 1987
- United States v. Bernice H. ShanbaumCourt of Appeals for the Fifth Circuit · 1994
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3Cited by3 opinions
- Byrd v. Bank of MississippiDistrict Court, S.D. Mississippi · 1997
- El Paso Refining, Inc. v. Internal Revenue ServiceDistrict Court, W.D. Texas · 1996
- Jet Sales West LLC v. City of El PasoUnited States Bankruptcy Court, D. New Mexico · 2021