Hugh D. Summers and Teresa E. Summers - Page 5

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               On November 19, 1999, Commonwealth dismissed with prejudice            
          its claim against respondent and gave respondent a check in the             
          amount of $15,000 to discharge the tax lien on the Montgomery               
          County property.  Respondent applied the payment to petitioners’            
          1985 tax liabilities.                                                       
               Mr. Summers’s Bankruptcy Litigation                                    
               On October 9, 1998, Mr. Summers filed a chapter 7 bankruptcy           
          petition in the U. S. Bankruptcy Court for the Eastern District             
          of Pennsylvania (the bankruptcy court), In re Hugh D. Summers,              
          No. 98-33068F.  During November 1999, respondent filed a                    
          complaint with the bankruptcy court asserting that Mr. Summers’s            
          tax liabilities, including those for 1989, and interest thereon             
          were not dischargeable pursuant to 11 U.S.C. section                        
          523(a)(1)(C).  Respondent conceded that the penalties and                   
          interest on the penalties were dischargeable.                               
               On January 11, 2001, the bankruptcy court held that Mr.                
          Summers’s tax liabilities were nondischargeable because he                  
          wilfully attempted to evade payment of his taxes.  See United               
          States v. Summers, 266 Bankr. 292 (Bankr. E.D. Pa. 2001).                   
               Actions Against Mr. Summers To Reduce Federal Tax Claims To            
          Judgment                                                                    
               On April 3, 2002, respondent filed a complaint against Mr.             
          Summers in the United States District Court for the Eastern                 
          District of Pennsylvania (the District Court) seeking to reduce             
          to judgment the tax assessments against Mr. Summers, including              





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