- 3 - 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 followingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011