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IN RE SIENEGA

BAP No. EC-19-1334-FLS Bk. No. 14-30986-B-7 Adv. No. 18-02191.

619 B.R. 405 (2020)

IN RE: Rudolf P. SIENEGA, Debtor. Rudolf P. Sienega, Appellant, v. State of California Franchise Tax Board, Appellee.

United States Bankruptcy Appellate Panel of the Ninth Circuit.

Filed October 5, 2020.

Attorney(s) appearing for the Case

Robert L. Goldstein argued for appellant;

Donny P. Le argued for appellee.

Before: FARIS, LAFFERTY, and SPRAKER, Bankruptcy Judges.

OPINION

INTRODUCTION

Chapter 71 debtor Rudolf P. Sienega failed to file state tax returns for four years in the 1990s. After receiving notices of federal tax adjustments from the Internal Revenue Service ("IRS") and an adverse...

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