Legal Opinion
Pransky v. Internal Revenue Service (In Re Pransky)
United States Bankruptcy Court, D. New Jersey
Decided November 3, 1999No. 16-22158PublishedCited by 2 opinions
1Opinion of the Court
OPINION
WILLIAM H. GINDIN, Bankruptcy Judge.
PROCEDURAL HISTORY
This dispute arises out of a proof of claim filed by the Internal Revenue Service (“IRS”) against Roger Pransky for the unpaid portion of an asserted tax liability. Both debtor and the IRS have submitted motions for summary judgment. The issue before this court is whether or not debtor’s remittances constitute payments or deposits for purposes of 26 U.S.C. § 6511.
This court conducted a hearing on this matter on July 2, 1999, and reserved decision. Counsel for both parties submitted supplemental memoranda.
This court finds, for the…
2Cases cited22 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. BoyleSupreme Court of the United States · 1985
- United States v. SullivanSupreme Court of the United States · 1927
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3Cited by2 opinions
- Internal Revenue Service v. PranskyDistrict Court, D. New Jersey · 2001
- Pransky v. Internal Revenue Service (In re Pransky)United States Bankruptcy Court, D. New Jersey · 2004