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17, 1996, respondent filed a proof of claim in petitioners’
bankruptcy proceeding. Respondent’s claim consisted of estimated
liabilities because petitioners had not filed tax returns. On
June 16, 1997, the bankruptcy court compelled petitioners to file
Federal income tax returns for their 1993, 1994, and 1995 tax
years. The returns were to be filed within 3 years of the date
of petitioners’ bankruptcy petition.
On the basis of the tax liability petitioners reported,
respondent filed his first, second, and third amendments to the
proof of claim on or about December 16, 1997, March 10, 1998, and
February 9, 1999, respectively. On February 9, 1999,
respondent’s unsecured priority claims were as follows:
Unsecured Priority Claims
Year Tax Due Interest to Bankruptcy Petition Date
1993 $41,517 $9,123.09
1994 2,163 258.80
1995 1 -0-
1996 2,191 -0-
At the same time, respondent’s unsecured general claims totaled
$20,090.
On October 5, 1999, petitioners’ Fourth Amended Plan of
Reorganization was confirmed by the bankruptcy court. On or
about June 5, 2000, respondent mailed a statutory notice of
deficiency to petitioners determining income tax deficiencies and
additions to tax for their 1993, 1994, and 1995 tax years. The
deficiencies, if approved, would result in the following
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Last modified: May 25, 2011