- 6 -
upon petitioner pursuant to section 6673(a). Howard v.
Commissioner, T.C. Memo. 2002-85.
Petitioner did not file an appeal in respect of any of the
Court's decisions cited above. Each of those decisions is now
final. Sec. 7481(a).
Petitioner's Bankruptcy Proceedings
On June 14, 1991, petitioner filed a bankruptcy petition
under chapter 13 of the Bankruptcy Code with the U.S. Bankruptcy
Court for the District of Arizona. On July 24, 1996, the
bankruptcy court issued an order dismissing petitioner's case.
This order was affirmed on appeal to the U.S. District Court for
the District of Arizona on September 9, 1997.
On December 6, 1996, petitioner filed a bankruptcy petition
under chapter 7 of the Bankruptcy Code with the U.S. Bankruptcy
Court for the District of Arizona. On April 7, 1997, the
bankruptcy court entered an order of discharge in petitioner's
case.
On April 16, 1999, petitioner filed a bankruptcy petition
under chapter 13 of the Bankruptcy Code with the U.S. Bankruptcy
Court for the District of Arizona. On April 20, 1999, the
bankruptcy court entered an order granting the Commissioner's
motion for relief from the automatic stay, see 11 U.S.C. sec.
362(a) (2000), regarding petitioner's tax liabilities for 1993,
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