Brandon Christopher Merriweather - Page 2

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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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