Washington v. Comm'r
United States Tax Court
Held: The Court has jurisdiction to determine whether the U.S. Bankruptcy Court discharged petitioners from their respective unpaid Federal income tax (tax) liabilities for their taxable years 1994 and 1995. Held, further, The U.S. Bankruptcy Court did not discharge petitioners from such liabilities.
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Held: The Court has jurisdiction to determine whether the U.S. Bankruptcy Court discharged petitioners from their respective unpaid Federal income tax (tax) liabilities for their taxable years 1994 and 1995. Held, further, The U.S. Bankruptcy Court did not discharge petitioners from such liabilities. Held, further, Respondent's application of petitioners' overpayment for their taxable year 1997 as a credit against their unpaid tax liability for their taxable year 1990, and not 1998, was proper. See sec. 6402(a), I.R.C. Held, further, Respondent may proceed with the collection action as…
1Opinion of the Court
Chiechi, Judge:
The petition in this case was filed in response to a notice of determination concerning collection action(s) under section 6320 and/or 63301 (notice of determination).
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
At the time petitioners filed the petition in this case, they resided in New York, New York.
On December 12, 1996, petitioners jointly filed late Form 1040, U.S. Individual Income Tax Return (Form 1040), for each of their taxable years 1994 (1994 return) and 1995 (1995 return).2 In their 1994 return, petitioners reported that they owed $6,680…
2Cases cited12 opinions
- Young v. United StatesSupreme Court of the United States · 2002
- Woodral v. CommissionerUnited States Tax Court · 1999
- Katz v. CommissionerUnited States Tax Court · 2000
- Magana v. Comm'rUnited States Tax Court · 2002
- In Re GucciCourt of Appeals for the Second Circuit · 1997
7 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Swanson v. Comm'rUnited States Tax Court · 2003
- In Re OttoUnited States Bankruptcy Court, E.D. Pennsylvania · 2004
- Bussell v. Comm'rUnited States Tax Court · 2008
- Enos v. Comm'rUnited States Tax Court · 2004
- Severo v. Comm'rUnited States Tax Court · 2007
43 more not listed; retrieve them via the Exa API.