IN RE FREYTAG

Bankruptcy No. 390-30082-HCA-7. Civ. A. No. 3:93-CV-2094-G.

173 B.R. 330 (1994)

In re Thomas L. FREYTAG and Sharon N. Freytag, Debtors. James W. CUNNINGHAM and Sharon N. Freytag, Appellants, v. UNITED STATES of America, Appellee.

United States District Court, N.D. Texas, Dallas Division.

August 22, 1994.


Attorney(s) appearing for the Case

Harold C. Abramson, pro se.

Charles B. Hendricks, Law Office of Charles B. Hendricks, Dallas, TX, for James W. Cunningham.

Alan Wright, Haynes & Boone, William Doyle Elliott, Cowles & Thompson, Dallas, TX, for Sharon N. Freytag.

Louise Grace Parks Hytken, U.S. Dept. of Energy, Tax Div., Dallas, TX, for U.S.


MEMORANDUM ORDER

FISH, District Judge.

Before the court is the appeal of debtor Sharon Freytag ("Ms. Freytag") from an order of the bankruptcy court determining that she is not entitled to relief as an innocent spouse from the claims of the Internal Revenue Service ("IRS"). For the reasons stated below, the order of the bankruptcy court is affirmed.

I. BACKGROUND

Sharon and Thomas Freytag deducted substantial losses on their...

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