120 T.C. No. 8
UNITED STATES TAX COURT
HOWARD AND EVERLINA WASHINGTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11152-01L. Filed March 6, 2003.
Held: The Court has jurisdiction to determine
whether the U.S. Bankruptcy Court discharged petition-
ers from their respective unpaid Federal income tax
(tax) liabilities for their taxable years 1994 and
1995. Held, further, The U.S. Bankruptcy Court did
not discharge petitioners from such liabilities.
Held, further, Respondent’s application of peti-
tioners’ overpayment for their taxable year 1997 as a
credit against their unpaid tax liability for their
taxable year 1990, and not 1998, was proper. See sec.
6402(a), I.R.C.
Held, further, Respondent may proceed with the
collection action as determined in the notice of deter-
mination with respect to each of petitioners’ taxable
years 1994, 1995, and 1998.
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