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a "continuing injunction" against the Internal Revenue Service
(IRS) insofar as the IRS had filed a claim with the court.
Petitioner subsequently filed an appeal challenging the dismissal
of his chapter 13 bankruptcy case with the U.S. District Court
for the District of Arizona.
On December 6, 1996, petitioner filed a petition for relief
under chapter 7 of the Bankruptcy Code with the U.S. Bankruptcy
Court for the District of Arizona.
On March 6, 1997, respondent issued a notice of deficiency
to petitioner determining a deficiency in his Federal income tax
for 1993 in the amount of $3,136, as well as an addition to tax
pursuant to section 6651(a)(1) in the amount of $784.
On April 7, 1997, the bankruptcy court issued an order of
discharge in petitioner's chapter 7 bankruptcy case.
On August 22, 1997, respondent issued notices of deficiency
to petitioner determining deficiencies in and additions to his
Federal income taxes for the taxable years and in the amounts as
follows:
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1994 $4,162 $775.75 $154.91
1995 10,146 2,254.50 482.15
On September 6, 1997, the U.S. District Court for the
District of Arizona denied petitioner's appeal of the dismissal
of his chapter 13 bankruptcy case.
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