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collection of his 1997 tax liability.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the attached exhibits, and our findings
in Merriweather v. Commissioner, T.C. Memo. 2001-88, are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Memphis, Tennessee.
Personal Background/History
From 1990 until early 1996, petitioner and Linda Harrell
(Ms. Harrell) lived together. Petitioner and Ms. Harrell were
never married.
Ms. Harrell has three children: Ricky Harrell, Jr., Calesa
Harrell (Calesa), and Gabriel Harrell born January 12, 1987,
December 28, 1992, and September 27, 1996, respectively. Ricky
Harrell, Sr.,3 is Ricky Harrell, Jr.’s, father. Orlando
Patterson is Gabriel Harrell’s father. Ms. Harrell is Calesa’s
biological mother. Until sometime in 1995, petitioner thought
2 In Merriweather v. Commissioner, T.C. Memo. 2001-88, we
granted respondent’s Motion To Dismiss the Tax Years 1995 and
1996 for Failure to State a Claim upon Which Relief Can Be
Granted because (1) his only argument regarding 1995 and 1996 was
that he wanted to contest the underlying liabilities for those
years, (2) he received a notice of deficiency for 1995 and 1996,
and (3) pursuant to sec. 6330 he is barred from contesting his
underlying liabilities for 1995 and 1996. This opinion addresses
petitioner’s 1997 taxable year on which we concluded he could
proceed forward. Id.
3 Ms. Harrell was married to Ricky Harrell, Sr., when
Calesa was born and is still married to Ricky Harrell, Sr.
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