Bryen v. United States (In re Bryen)

Pre 2005-Act: 
Pre 2005-Act
Ruling: 
Prior actions in which debtor was not fully represented or which determined debtor did not engage in sham transactions did not establish dischargeability of tax debt.
Procedural posture: 
Plaintiff bankruptcy debtor brought an adversary proceeding against defendant United States seeking a determination that the debtor's tax liability to the government was discharged. The government moved for summary judgment on the ground that collateral estoppel established that the debtor willfully attempted to evade the taxes, which rendered the tax debt nondischargeable under 11 U.S.C.S. § 523(a)(1)(C).
Issue: 
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Consumer case opionion summary, case decided on November 24,2008, LexisNexis #0909-032