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petitioner was liable for the following deficiencies and
additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1993 $8,307 $896 ---
1994 8,460 2,115 $436
1995 10,657 2,524 548
In June 1998, respondent assessed the deficiencies and additions
to tax decided in the Court’s order of dismissal and decision.
Copies of MFTRA-X transcripts reflect that interest on the taxes
was also assessed in June 1998.2
On August 5, 1998, petitioner filed a bankruptcy petition
under chapter 7 of the U.S. Bankruptcy Code in the U.S.
Bankruptcy Court for the Northern District of Texas. On Schedule
E, Supplemental Income and Loss, petitioner reported the Internal
Revenue Service (IRS) as the holder of unsecured priority claims
for the years 1993, 1994, and 1995. On December 7, 1998, the
bankruptcy court entered an order of discharge (discharge order)
in petitioner’s bankruptcy case. The discharge order states:
DISCHARGE OF DEBTOR
It appearing that a petition commencing a case under
title 11, United States code, was filed by or against
the person named above on 08/05/98, and that an order
for relief was entered under chapter 7, and that no
complaint objecting to the discharge of the debtor was
2We shall refer to the unpaid balance of assessment for
petitioner’s taxable years 1993, 1994, and 1995 as petitioner’s
unpaid liability for each of those years. See Washington v.
Commissioner, 120 T.C. 114, 116 (2003).
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