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did not provide current financial information was an abuse of
discretion. We hold that it was not.
Section references are to the Internal Revenue Code in
effect for the applicable years. Rule references are to the Tax
Court Rules of Practice and Procedure.
Background
The parties submitted this case fully stipulated under Rule
122.
A. Petitioner
Petitioner resided in Springfield, Virginia, when she filed
the petition in this case. In 1997, she was a budget analyst for
the U.S. Department of Commerce, and her husband, Mr. Moorhous,
was a retired U.S. Department of Defense employee. Petitioner
and Mr. Moorhous filed joint income tax returns for 1989-92.1
Petitioner and Mr. Moorhous filed separate bankruptcy
petitions on dates not stated in the record. Petitioner’s income
tax liability for 1987 and 1988 was discharged in bankruptcy, but
Mr. Moorhous’s liability for those years was not discharged.
1 Mr. Moorhous is not a party to this case. He received a
Notice of Determination Concerning Collection Action(s) Under
Sec. 6320 and/or 6330, but he filed his request for a hearing
late. Thus, he is not entitled to judicial review under sec.
6320 or sec. 6330. Moorhous v. Commissioner, 116 T.C. 263, 270
(2001); Kennedy v. Commissioner, 116 T.C. 255, 262-263 (2001).
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