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The Bankruptcy Case
On May 5, 1995, petitioner and her husband filed a voluntary
petition for liquidation under chapter 7 of the U.S. Bankruptcy
Code in the U.S. Bankruptcy Court for the Western District of
Pennsylvania (the bankruptcy case). In the bankruptcy case,
respondent filed a $379,025.90 proof of claim. On June 17, 1996,
the bankruptcy court granted the Doyles a discharge pursuant to
11 U.S.C. sec. 727.
In this case, petitioner initially contended that the income
taxes at issue were discharged in the bankruptcy case. Petitioner
conceded before trial that her joint and several income tax
liabilities for the years 1980 through 1983 were excepted from
bankruptcy discharge pursuant to 11 U.S.C. sec. 523(a)(1)(C).
Payment of Tax Deficiencies
The Doyles have not made any voluntary payments on their
assessed tax liabilities. During 1994 and 1995, respondent
placed a continuing levy on the wages of petitioner’s husband
which resulted in the receipt of $34,672.71 and $14,132.45,
respectively. On June 5, 1995, respondent applied a $6,345
overpayment due the Doyles to their 1980 tax liability. In
addition, respondent retained the following refunds due the
Doyles to offset their assessed tax liabilities:
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Last modified: May 25, 2011