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May 16, 1984. Following a jury trial in June 1991, petitioner
was acquitted of all charges.
Petition in Bankruptcy
On March 15, 1993, petitioner filed a petition under chapter
7 of title 11 of the U.S. Code. The schedule of debts annexed to
the petition filed in that proceeding listed the IRS as a
creditor in the amount of $86,504 for the taxable years 1984,
1986, and 1987. On June 22, 1993, the bankruptcy court entered
an order releasing petitioner from all dischargeable debts.
Petitioner was represented in the bankruptcy proceeding by Roger
McShea (McShea). McShea never received any contact from the IRS
concerning the attempted discharge of petitioner's taxes.
INI
On October 14, 1991, INI was involuntarily dissolved by the
Alaska commissioner of corporations. On August 20, 1993,
respondent sent notices of deficiency to INI for TYE 9/84, in
care of petitioner, and to petitioner for 1984 and 1986. The
deficiency determined against INI is attributable to the
disallowance in full of the deduction claimed in respect of the
$100,000 accrual of the bonus payable to Burke. On November 16,
1993, petitioner filed a petition with this Court on behalf of
himself and INI.
The parties have stipulated that INI's current and
accumulated earnings and profits for the years in issue were
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