121 T.C. No. 7
UNITED STATES TAX COURT
NEAL SWANSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6440-01L. Filed August 28, 2003.
P did not file Federal income tax returns for the
years 1993, 1994, and 1995. R subsequently prepared
substitutes for return (SFRs) for P and issued a notice
of deficiency to P based on the SFRs covering these
years. P filed a petition to this Court, but P’s case
was later dismissed, and a decision was entered for R
because P failed to state a claim upon which relief
could be granted. R assessed the tax liabilities for
the years 1993, 1994, and 1995. P subsequently filed a
petition under ch. 7 of the U.S. Bankruptcy Code. The
bankruptcy court entered an order generally releasing P
from all dischargeable debts. The bankruptcy court did
not expressly determine whether P’s unpaid tax
liabilities were discharged. R issued a notice of
intent to levy, and P requested a hearing before an IRS
Appeals officer (A) pursuant to sec. 6330, I.R.C. At
the hearing, P claimed that his unpaid liabilities were
discharged in bankruptcy. A issued a notice of
determination sustaining the levy, and P timely
petitioned the Court for review.
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