Legal Opinion

Freytag v. Commissioner

United States Tax Court

Decided February 5, 1998No. Tax Ct. Dkt. No. 13538-86Published

R issued a notice of deficiency to Ps for the taxable years 1978, 1981, and 1982. Ps filed a petition with this Court and subsequently filed a petition in bankruptcy with the bankruptcy court.

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R issued a notice of deficiency to Ps for the taxable years 1978, 1981, and 1982. Ps filed a petition with this Court and subsequently filed a petition in bankruptcy with the bankruptcy court. R filed proofs of claim for the taxable years 1978, 1981, and 1982 pursuant to 11 U.S.C. sec. 505(a)(1) (1994) (Bankruptcy Code). P Sharon filed an objection to R's proofs of claim on the grounds that she is an innocent spouse pursuant to sec. 6013(e), I.R.C., and sec. 6004 of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3685. The bankruptcy court determined,…

1Opinion of the Court

THOMAS L. FREYTAG AND SHARON N. FREYTAG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Freytag v. Commissioner

Tax Ct. Dkt. No. 13538-86

United States Tax Court

110 T.C. 35; 1998 U.S. Tax Ct. LEXIS 6; 110 T.C. No. 5;

February 5, 1998, Filed

An Order and Decision will be entered denying petitioner's motion for summary judgment, and the decision entered will be consistent with the order of the bankruptcy court.

R issued a notice of deficiency to Ps for the taxable years 1978, 1981, and 1982. Ps filed a petition with this Court and subsequently filed a petition in bankruptcy with the…

2Cases cited25 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Freytag v. CommissionerSupreme Court of the United States · 1991
  3. United States v. RodgersSupreme Court of the United States · 1983
  4. Begier v. Internal Revenue ServiceSupreme Court of the United States · 1990
  5. Freytag v. CommissionerUnited States Tax Court · 1987

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