Jeffrey K. Ramsdell - Page 2

                                        - 2 -                                          
          Section 6330 (Notice of Determination).  The substantive issue to            
          be decided is whether petitioner’s 1992 and 1993 tax liabilities             
          were discharged in bankruptcy.  For the reasons stated below, we             
          grant respondent’s motion.                                                   
                                      Background                                       
               The record shows and/or the parties do not dispute the                  
          following.2                                                                  
               Petitioner failed to file timely Federal income tax returns             
          for 1992 and 1993.  He filed the returns for both years on August            
          5, 2001.                                                                     
               On August 2, 2001, 3 days before filing the 1992 and 1993               
          returns, petitioner filed for chapter 7 bankruptcy in the U.S.               
          Bankruptcy Court for the Northern District of California.  In his            
          Schedule E, Creditors Holding Unsecured Priority Claims,                     
          petitioner listed his liability to respondent as $10,9603 plus               
          penalties and interest for the taxable years 1992, 1993, and                 
          1994.4  On November 6, 2001, the bankruptcy court issued an order            
          stating that petitioner “is/are granted a discharge under section            
          727 of Title 11, United States Code (the Bankruptcy Code).”                  




               2 At the time he filed the petition, petitioner resided in              
          Sausalito, California.                                                       
               3 All dollar amounts have been rounded to the nearest                   
          dollar.                                                                      
               4 The taxable year 1994 is not at issue here.                           




Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011