- 3 -
In his motion to reconsider our decision in Harrell,
respondent argues that the “Court’s disposition of this case
constitutes both substantial error and unusual circumstances.”
Background
We adopt the findings of fact in our prior memorandum
opinion, Harrell v. Commissioner, supra. For convenience we
repeat the facts necessary to elucidate the ensuing discussion.
Respondent issued to petitioners a “NOTICE OF DETERMINATION
CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330”
dated January 22, 2002 (Notice of Determination). The Notice of
Determination dealt with petitioners’ income tax liabilities for
tax years 1991, 1992, 1993, and 1999.
Petitioner Edward H. Harrell filed for chapter 11 bankruptcy
on October 24, 1995. Petitioner Anne G. Harrell filed for
chapter 11 bankruptcy on December 18, 1996. Petitioners’ chapter
11 bankruptcy cases were consolidated on February 27, 1997.
Their consolidated chapter 11 bankruptcy case was dismissed on
June 30, 1997.
On the same day as the dismissal of their chapter 11
bankruptcy case, petitioners filed a petition for chapter 7
bankruptcy relief. Petitioners were granted a discharge in their
chapter 7 bankruptcy case on June 11, 1998.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011