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OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's motion to dismiss for lack of
jurisdiction and to strike as to the taxable years 1989, 1990,
1991, and 1993. The question to be decided is whether the
petition for redetermination was filed with the Court within the
period prescribed in section 6213(f).
Background
On June 14, 1991, petitioner filed a voluntary petition for
relief under chapter 13 of the Bankruptcy Code with the U.S.
Bankruptcy Court for the District of Arizona.
On February 21, 1992, respondent mailed a notice of
deficiency to petitioner determining a deficiency in his Federal
income tax for 1989 in the amount of $4,733, as well as additions
to tax in the amounts of $1,182.50 and $320.01 pursuant to
sections 6651(a) and 6654(a), respectively.
On June 23, 1993, respondent mailed a notice of deficiency
to petitioner determining deficiencies in and additions to his
Federal income taxes for 1990 and 1991 as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1990 $8,419 $2,105 $554
1991 5,483 1,371 318
On July 24, 1996, the bankruptcy court entered an order
granting the bankruptcy trustee's motion to dismiss petitioner's
case. The bankruptcy court also denied petitioner's request for
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