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In the motion, respondent contends that the Court should
sustain additions to tax for the taxable years 1985 and 1986, in
the amounts of $7,242 and $5,580, respectively, pursuant to
section 6651(a).
Background
In two notices of deficiency, both dated February 23, 1994,
respondent determined that there are additions to tax due from
petitioner pursuant to section 6651(a) for the taxable years 1985
and 1986, in the amounts of $7,242 and $5,580, respectively. The
section 6651(a) late filing addition is the only issue in this
case.
Petitioner resided in Kennewick, Washington, when he filed
his petition on May 9, 1994. After several procedural matters
were resolved by Order dated January 22, 1996, respondent filed a
Notice of Proceeding in Bankruptcy on July 22, 1996. By Order
dated July 24, 1996, pursuant to 11 U.S.C. section
362(a)(8)(1994), all proceedings before this Court were
automatically stayed. In a status report filed September 27,
1996, respondent informed the Court that petitioner received a
discharge in his bankruptcy case on August 22, 1996. Thereafter,
on September 27, 1996, we issued an Order lifting the stay of
proceedings. On August 7, 1997, respondent filed the present
motion. We notified petitioner of the filing and requested that
he file an objection with the basis therefor, on or before
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