- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011