- 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