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(1) Whether the amount assessed in each year at issue was
correct; (2) whether petitioner’s April 7, 1994, bankruptcy
filing barred the assessment of his 1994 income tax liability;
(3) whether the assessments for the tax years at issue were
timely; (4) whether penalties under section 6651(a)(2) should be
abated; (5) whether interest on the tax liabilities for all tax
years at issue should be abated; (6) whether petitioner received
proper notice of the filing of the NFTL; and (7) whether
collection alternatives were properly considered.
FINDINGS OF FACT
Petitioner resided in Torrance, California, when he filed
the petition. Prior to becoming a California resident, he was a
resident of New Orleans, Louisiana.
Petitioner filed tax returns in which he reported income of
$37,353 for 1992, $12,265 for 1993, and $8,123 for 1994, and
income taxes due of $4,924.32, $2,874.95, and $1,133.74, for
those respective years. Petitioner failed to pay the income
taxes due other than a partial payment of $156 for 1994.
Respondent assessed petitioner's 1992-94 Federal income tax
liabilities on September 20, 1993, August 5, 1996, and October 9,
1995, respectively. The assessment for each tax year was made
within 3 years from the date the return for that year was filed.
Petitioner filed for bankruptcy on three separate occasions:
The bankruptcy proceeding filed on April 7, 1994, was dismissed
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