M. K. and J. C. H. - Page 1

                                   118 T.C. No. 20                                    

                             UNITED STATES TAX COURT                                  

              M. K. and J. C. H., Petitioners v.                         
                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       

              Docket No. 9260-00.          Filed April 22, 2002.                      

                   Ps filed for a ch. 11 reorganization in                            
              bankruptcy.  R filed a proof of claim setting forth                     
              income tax liabilities for 3 taxable years.  The                        
              bankruptcy court ordered Ps to file returns.  After the                 
              returns were filed, R made amendments to his proof of                   
              claim.  Ps did not object to the tax liabilities set                    
              forth in R’s claim, and the bankruptcy court confirmed                  
              the plan of reorganization without deciding the merits                  
              of Ps’ tax liabilities.  Following the bankruptcy                       
              court’s confirmation of the plan, R determined income                   
              tax deficiencies and additions to tax for the same 3                    
              taxable years.  The deficiencies, if approved, would                    
              result in tax liabilities exceeding those already                       
              claimed by R in the bankruptcy.  Ps contend that R is                   
              estopped from determining deficiencies for the same tax                 
              years already claimed in Ps’ bankruptcy reorganization.                 

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