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On or about June 5, 1996, petitioner mailed to the Court a
petition for redetermination (the petition) in respect of the
notice of deficiency. The petition was received and filed by the
Court on June 12, 1996.
In the petition, petitioner alleged, in part, that the Forms
1099-G were duplicates of a single indebtedness owed by
petitioner and that such indebtedness had been discharged in
petitioner's prior bankruptcy case.
At the time that the petition was filed, petitioner's net
worth did not exceed $2,000,000.
On June 18, 1996, petitioner's counsel contacted Pat Joiner,
an employee of the FDIC, and requested a letter explaining the
Forms 1099-G that had been sent to petitioner.
On June 19, 1996, Marsha Kish (Ms. Kish), a tax examiner at
the Austin service center to whom petitioner's case had been
assigned, contacted petitioner's counsel. Petitioner's counsel
explained that the discharge of indebtedness reflected on the
Forms 1099-G represented a single debt incurred by petitioner to
Moncor Bank and that this debt was discharged in bankruptcy in
September 1986. Petitioner's counsel told Ms. Kish that he had
requested the FDIC to send him a letter explaining the Forms
1099-G. Ms. Kish asked petitioner's counsel to send her a copy
of such letter as soon as possible; petitioner's counsel agreed
to forward her a copy upon receipt.
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