Wheeler v. Commissioner of Internal Revenue

1 Citing case

  1. Boudreau v. United States

    622 B.R. 817 (B.A.P. 1st Cir. 2020)   Cited 9 times
    Holding that proceeding to determine the scope of the debtor's discharge arises under the Bankruptcy Code and that the bankruptcy court therefore has jurisdiction over them "regardless of . . . whether there is a potential impact on the bankruptcy estate or the distribution to creditors"

    The U.S. Tax Court has "repeatedly confirmed that a Form 4340 can provide the basis for finding that a taxpayer has not filed a return." Wheeler v. Comm'r, 446 F. App'x 951, 953 (10th Cir. 2011) (citing Hazel v. Comm'r, 95 T.C.M. (CCH) 1528, 2008 WL 2095614, at *2-3 (2008) (collecting cases)). Accordingly, the IRS met its evidentiary burden.