A Prior Bankruptcy Decision Bars Challenge to Tax Deficiency and Innocent Spouse Relief
A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.
The United States Tax Court, sustaining a collection action, held that the doctrine of res judicata bars a married couple from challenging the timeliness and validity of notices of deficiency, finding that those issues were previously resolved during bankruptcy proceedings, and that res judicata also bars the wife from seeking innocent spouse relief.
RICHARD E. SNYDER AND MARION B. SNYDER,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
RICHARD E. SNYDER AND MARION SNYDER,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent