- 2 - otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. Background Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioners resided in Raymore, Missouri, at the time they filed their petition. Assessments were made against petitioners for Federal income tax for 1981, 1982, and 1983; the assessments were related to petitioners’ investments in the early 1980's in tax shelter activities. Petitioners filed for bankruptcy on July 29, 1994. The Internal Revenue Service (IRS) filed a proof of claim in the bankruptcy case for 1981, 1982, and 1983 Federal income taxes. Petitioners objected to the IRS proof of claim related to the 1983 tax liability in the bankruptcy case but later withdrew that objection. On December 22, 1994, the Bankruptcy Court granted petitioners a discharge. Petitioners’ tax liability for 1981 and 1982 was not discharged in the bankruptcy. Petitioners’ tax liability for 1983 was discharged in the bankruptcy, but the discharge does not prevent the collection of the 1983 liability from property that was exempt from the bankruptcy estate. Petitioners were aware that the IRS retained the right to levy on their exempt assets. Petitioners’ withdrawal of their objectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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