3
Petitioner signed a Stipulation of Settlement for Tax
Shelter Adjustments of Petitioners (the Stipulation), filed with
the Court on January 14, 1991. In the Stipulation, petitioner
agreed that all adjustments in the notice of deficiency related
to the Encore Leasing tax shelter, and petitioner agreed to have
all issues in her case resolved as if petitioner were the same as
the taxpayer in the controlling case, Wolf v. Commissioner,
docket No. 28585-86. The Stipulation provided that a decision
would be submitted in her case when the decision in the
controlling case became final. Keith A. Zavitz signed an
identical stipulation. An opinion was entered in Wolf v.
Commissioner on May 15, 1991, T.C. Memo. 1991-212. This decision
was affirmed. Wolf v. Commissioner, 4 F.3d 709 (9th Cir. 1993).
No signed decision document has been submitted.
Petitioner and Mr. Zavitz are no longer married. It is not
clear from the record when they separated or divorced.
On August 5, 1992, petitioner filed a petition with the U.S.
Bankruptcy Court for the Eastern District of California under
chapter 7 of the Bankruptcy Code (title 11, U.S.C.). On December
9, 1993, petitioner was granted a discharge in bankruptcy. The
Order provided that petitioner was released from all
dischargeable debts. The Order further provided:
2. Any judgment heretofore or hereafter obtained in any
court other than this court is null and void as a
determination of the personal liability of the debtor with
respect to any of the following:
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