§365
14 cases·2 questioned·1 overruled·11 cited
Statute Text — 26 U.S.C. §365
Statute text not available for this section.
14 Citing Cases
365(a)(8) (2012), petitioner timely filed his petitions in these three cases, which were consolidated for trial, briefing, and opinion. OPINION The Commissioner's determinations in a notice ofdeficiency are generally presumed correct, and the taxpayerbears the burden ofproving those determina- tions erroneous. Rule 142(a); Welch v. Helvering,
365(a)(8) (2012), petitioner timely filed his petitions in these three cases, which were consolidated for trial, briefing, and opinion. OPINION The Commissioner's determinations in a notice ofdeficiency are generally presumed correct, and the taxpayerbears the burden ofproving those determina- tions erroneous. Rule 142(a); Welch v. Helvering,
365(a)(8) (2012), petitioner timely filed his petitions in these three cases, which were consolidated for trial, briefing, and opinion. OPINION The Commissioner's determinations in a notice ofdeficiency are generally presumed correct, and the taxpayerbears the burden ofproving those determina- tions erroneous. Rule 142(a); Welch v. Helvering,
section 365(d)(1): “In a case under chapter 7 of this title, if the [bankruptcy] trustee does not assume or reject an executory contract * * * of the debtor within 60 days after the order for relief * * * then such contract or lease is deemed rejected.” Under this statute, petitioners argue that the period of limitations extension for Form 872-A ex