- 3 -
Swiss Haus, Inc. for the quarter ending December 31, 1982, to the
quarter ending June 30, 1984. See sec. 6672.
In December 1990, the U.S. Bankruptcy Court for the Northern
District of Ohio, Eastern Division, entered an order requiring
the chapter 7 trustee to pay certain administrative claimants a
dividend, including $12,802 to respondent on its claim for
administrative taxes incurred by petitioners’ bankruptcy estate
during the chapter 11 phase of the case. Further, the TFRP
liabilities were found not to be fully dischargeable in
bankruptcy. See 11 U.S.C. sec. 523(a)(1)(A) (2000).
Petitioners filed their 1990, 1991, and 1992 tax returns
with the filing status of married filing jointly and did not send
in payments for the balances due with these returns. Mr. Lah
filed his 1993 tax return with the filing status of married
filing separately. Mr. Lah did not send in a payment for the
balance due with his 1993 tax return.
Prior to September 1996, petitioners sent in various partial
payments to be applied to the income tax liabilities for the
years in issue. Petitioners would designate each payment to the
tax year that they wanted the payment to apply. During this
period, respondent would honor petitioners’ designations and
apply the payments to the tax years specified.
On July 12, 1996, petitioners entered into an installment
agreement with respondent that included the TFRP liabilities and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011