Claude D. Mayo, Sr. and Lessie M. Mayo - Page 2

                            T.C. Summary Opinion 2003-51                              


                               UNITED STATES TAX COURT                                


               CLAUDE D. MAYO, SR. AND LESSIE M. MAYO, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     


               Docket No. 14686-99S.            Filed May 14, 2003.                   

               Claude D. Mayo Sr. and Lessie M. Mayo, pro se.                         
               Dustin M. Starbuck, for respondent.                                    
          __________________                                                          
          *    On Sept. 20, 2001, this Court filed its Summary Opinion                
          (T.C. Summary Opinion 2001-146) in this case, and a decision was            
          entered on Jan. 15, 2002.  On Feb. 19, 2002, respondent notified            
          the Court that petitioner Claude D. Mayo, Sr. had filed a                   
          petition with the United States Bankruptcy Court for the Western            
          District of Virginia on Sept. 7, 1999, before the filing of our             
          opinion and entering the decision, but after the filing of the              
          petition.  Pursuant to 11 U.S.C  sec. 362(a)(8), on Feb. 20,                
          2002, we withdrew our opinion, vacated the decision, and stayed             
          the proceedings in this Court.  On Feb. 14, 2003, the Bankruptcy            
          Court lifted the stay imposed by 11 U.S.C. sec. 362(a)(8).  On              
          Mar. 3, 2003, this Court issued an order to show cause to                   
          petitioners as to why our opinion should not be released and our            
          decision entered.  Petitioners have not responded to that order.            
          The order to show cause has been made absolute.  Our Summary                
          Opinion, therefore, is unchanged.                                           





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