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misrepresentations (altered documents) which reflected that
petitioner had filed a bankruptcy petition, when in fact no
bankruptcy proceeding had commenced.
Background
On August 10, 1998, respondent mailed a notice of deficiency
to petitioners determining income tax deficiencies, additions to
tax, and accuracy-related penalties as follows:
Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1994 $58,746 $14,127 $28,843
1995 122,126 11,749 24,425
A petition was filed on October 7, 1998. An amended petition was
filed on October 28, 1998, and respondent’s answer was filed on
December 30, 1998.
This case was first set for trial on the June 21, 1999, Los
Angeles, California, trial session. On June 3, 1999, petitioner
advised respondent that he had voluntarily petitioned into a
chapter 7 (liquidating) bankruptcy (bankruptcy 1). In support of
petitioner’s claim, he provided respondent with what purported to
be a copy of petitioner’s bankruptcy petition. Petitioner’s
purported bankruptcy petition reflected the bankruptcy court
docket No. LA99-19644AA. On June 10, 1999, the parties engaged
in a telephone conference with the Court, at which time a
discussion of petitioner’s alleged bankruptcy petition ensued.
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