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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.
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