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Opinion 247

Case Name: 

Bowen v. Internal Revenue Serv. (In re Bowen), 84 B.R. 214 (Bankr.D.Utah)

Judge: 
Judge Boulden
Date: 
Mar-28-1988
Case Number(s): 
87PB-0236
Status: 

PUBLISHED

Body: 

The court considered the proper method of calculating penalties under Internal Revenue Code § 6700, which was enacted as part of an effort to eliminate abusive tax shelters. Having considered the arguments of both the IRS and the chapter 11 debtor subject to such penalties, the court determined that a transactional assessment of the penalty was not supportable, and that the penalty should be assessed on a one-time basis, rather than annually.

Internal Ref: 
Opinion 247
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