# Washington v. Comm'r

> United States Tax Court · March 6, 2003 · 120 T.C. 114

URL: https://www.frixlaw.com/law-library/cases/4474467

## Case

- **Full name:** HOWARD AND EVERLINA WASHINGTON v. COMMISSIONER OF INTERNAL REVENUE
- **Court:** United States Tax Court
- **Decided:** March 6, 2003
- **Citations:** 120 T.C. 114; 120 T.C. No. 8; 2003 U.S. Tax Ct. LEXIS 9
- **Precedential status:** Published
- **Opinion:** Concurrence by Wells
- **Judges:** "Chiechi, Carolyn P.","Wells, Thomas B.","Halpern, James S.",Beghe,"Vasquez, Juan F."
- **Cited by:** 57 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4474467

## How later opinions describe it (automated extraction)

- holding that the Court's jurisdiction allowed the Court to decide whether a bankruptcy court discharged the taxpayers from their unpaid Federal income tax liabilities

## Opinion text

Wells, C.J., concurring: I respectfully concur in this Court’s decision to exercise jurisdiction in the instant case to decide whether a tax liability has been discharged in bankruptcy. I write to note, however, that our Opinion does not necessarily preclude taxpayers from seeking review in an appropriate bankruptcy court after they have petitioned this Court. Although the issue to be decided in the instant case is relatively straightforward, it is possible that taxpayers will present this Court with more difficult questions that may be better suited for consideration by a bankruptcy court. Under such circumstances, this Court may defer to a bankruptcy court to decide the matter. Such deference would not be premised upon any concerns that we lack jurisdictional capacity to consider the issue. Rather, it would be based upon considerations of comity and judicial efficiency, combined with our recognition that this Court does not deal with bankruptcy matters with the expertise that a bankruptcy court possesses. See Kluger v. Commissioner, 83 T.C. 309, 320 (1984).
Gerber, Beghe, and Foley, JJ., agree with this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4474467. Public record. Not legal advice.