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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Last modified: May 25, 2011