T.C. Memo. 1996-296
UNITED STATES TAX COURT
TERRY R. HARDTKE AND NANCY HARDTKE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13669-92.1 Filed June 26, 1996.
Terry R. Hardtke, pro se.
Allan D. Hill, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following defi-
1 The proceedings herein were automatically stayed after the
trial herein when petitioners filed a petition for bankruptcy
with the U.S. Bankruptcy Court for the Northern District of
California on Sept. 30, 1993. On Oct. 18, 1995, after peti-
tioners' bankruptcy proceeding was discharged, the Court lifted
the automatic stay and ordered the parties to file simultaneous
opening briefs by Dec. 18, 1995, and simultaneous answering
briefs by Jan. 12, 1996. Petitioners did not file an opening
brief. On Jan. 17, 1996, petitioners submitted a document that
the Court had filed as their answering brief. On Jan. 18, 1996,
the Court ordered that petitioners were not allowed to file any
additional briefs in this case and that respondent was allowed to
file a reply to petitioners' answering brief, which she did on
Feb. 16, 1996.
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