Neal Swanson - Page 4

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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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