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addition to tax under section 6651(a) for failure to file a
timely return; and (3) whether petitioner is subject to the
addition to tax under section 6654 for failure to pay estimated
income tax.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Background
Petitioner was employed by the Federal Government during the
period 1970 through 1988. Petitioner has a master's degree in
library science, a master's degree in international law, and a
bachelor of laws degree. Petitioner and his spouse (the
McGuirls) owned several businesses and rental properties during
the 1980's.
1. The Bankruptcy Proceeding
The McGuirls were the subject of an involuntary petition in
bankruptcy filed under chapter 7 of the Bankruptcy Code on March
2, 1990. The petition was filed in the U.S. Bankruptcy Court for
the District of Columbia. The case was converted to a chapter 11
case for a short period of time in 1990, before being converted
back to a chapter 7 case. On January 25, 1994, the bankruptcy
court denied the McGuirls a discharge in the bankruptcy
proceeding.3
3 With certain exceptions, the filing of a petition under
the Bankruptcy Code operates as a stay of any civil action or
proceeding concerning the debtor or the debtor's property. 11
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