Galanis v. Commissioner
United States Tax Court
P filed his 1977 and 1978 Federal income tax returns on Oct. 13, 1978, and Oct. 22, 1979, respectively. An involuntary petition under chapter 7 of title 11, U.S.C. (the Bankruptcy Code), naming P as debtor was filed on May 1, 1980. On Nov. 9, 1984, the Bankruptcy Court dismissed P's case. On Mar. 21, 1986, R issued a notice of deficiency for P's taxable years 1977 and 1978. A timely petition was filed.
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P filed his 1977 and 1978 Federal income tax returns on Oct. 13, 1978, and Oct. 22, 1979, respectively. An involuntary petition under chapter 7 of title 11, U.S.C. (the Bankruptcy Code), naming P as debtor was filed on May 1, 1980. On Nov. 9, 1984, the Bankruptcy Court dismissed P's case. On Mar. 21, 1986, R issued a notice of deficiency for P's taxable years 1977 and 1978. A timely petition was filed. Held, sec. 6503(i), I.R.C. 1954, added by the Bankruptcy Tax Act of 1980, provides that the period of limitations is suspended for the prohibition period (automatic stay under 11 U.S.C. sec.…
1Opinion of the Court
OPINION
FAY, Judge:
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.1 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
This case is before the Court on petitioner’s motion for summary judgment. The sole issue for decision is whether the period for assessment expired under the statute of limitations with respect to petitioner’s taxable years 1977 and 1978, prior to the issuance of the notice of deficiency.
The facts of…
2Cases cited7 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Shiosaki v. CommissionerUnited States Tax Court · 1974
- Charlie Cox v. American Fidelity & Casualty Co., a Corporation and Underwriters at Lloyd's, LondonCourt of Appeals for the Ninth Circuit · 1957
- Giordano v. CommissionerUnited States Tax Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Moody v. CommissionerUnited States Tax Court · 1990
- Zimmerman v. CommissionerUnited States Tax Court · 1995
- Wekell v. United StatesDistrict Court, W.D. Washington · 1992
- Galanis v. CommissionerUnited States Tax Court · 1989
- Moody v. CommissionerUnited States Tax Court · 1990
1 more not listed; retrieve them via the Exa API.