- 4 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011