T.C. Memo. 2006-117
UNITED STATES TAX COURT
LEONARD O. PARKER, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 4053-03L. Filed June 8, 2006.
P filed a Motion for Reconsideration and a Motion
to Vacate challenging some of the Court’s factual and
legal conclusions.
P asserts that this Court erred by not finding R
violated the automatic bankruptcy stay imposed under 11
U.S.C. sec. 362(a) (1994), when R assessed P’s tax
liability for 1994 before the stay was lifted.
Held: The Government’s claim for P’s 1994 tax
liability arose no earlier than Dec. 31, 1994, and
therefore postdated the commencement of the case in
bankruptcy on April 7, 1994. Thus, the bankruptcy stay
did not bar the assessment of P’s 1994 income tax
liability.
* This Supplemental Memorandum Opinion supplements our prior
opinion in Parker v. Commissioner, T.C. Memo. 2006-43.
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