Severo v. Comm'r
United States Tax Court
With the late filing of their 1990 joint Federal income tax return, petitioners failed to pay most of the $ 63,499 taxes reported due. In 1994, petitioners filed a bankruptcy petition. In 1998, petitioners received a bankruptcy discharge order. In 2004, respondent levied against petitioners' $ 196 California income tax refund and notified petitioners of their appeal rights with regard thereto. Petitioners did not file an appeal.
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With the late filing of their 1990 joint Federal income tax return, petitioners failed to pay most of the $ 63,499 taxes reported due. In 1994, petitioners filed a bankruptcy petition. In 1998, petitioners received a bankruptcy discharge order. In 2004, respondent levied against petitioners' $ 196 California income tax refund and notified petitioners of their appeal rights with regard thereto. Petitioners did not file an appeal. In 2005, respondent mailed to petitioners a notice of Federal tax lien filing (NFTL) and a notice of intent to make a second levy. Petitioners requested an Appeals…
1Opinion of the Court
MICHAEL V. SEVERO AND GEORGINA C. SEVERO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Severo v. Comm'r
No. 6346-06L
United States Tax Court
129 T.C. 160; 2007 U.S. Tax Ct. LEXIS 36; 129 T.C. No. 17;
November 15, 2007, Filed
With the late filing of their 1990 joint Federal income tax return, petitioners failed to pay most of the $ 63,499 taxes reported due. In 1994, petitioners filed a bankruptcy petition. In 1998, petitioners received a bankruptcy discharge order.
In 2004, respondent levied against petitioners' $ 196 California income tax refund and notified petitioners of their…
2Cases cited18 opinions
- Young v. United StatesSupreme Court of the United States · 2002
- Everett v. JudsonSupreme Court of the United States · 1913
- Keith Orum and Cherie Orum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2005
- Orum v. Comm'rUnited States Tax Court · 2004
- KENNEDY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
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