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proceed with collection of petitioners’ joint Federal income tax
liabilities for the 1988, 1992, 1993, and 1997 tax years.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioners’ legal residence at the time the petition was filed
was Ranger, Georgia.
Petitioners previously lived and worked in Florida. Mr.
Roberts was a carpenter who worked generally as a handyman, and
Mrs. Roberts worked as a retail clerk.
Even though this case involved petitioners’ 1988, 1992,
1993, and 1997 tax years, petitioners had tax deficiencies for
several prior years. In 1990, petitioners filed a chapter 7
bankruptcy petition in which they listed total assets of $3,150
and liabilities of $1,896,695.60. The liabilities included
$14,533 in taxes owed to the United States; however, the tax
years for which the taxes were due were not indicated. The
record shows, however, that the deficiencies were from the
taxable years 1972, 1977, 1978, 1985, and 1986, but collection of
the deficiencies for the years 1972, 1977, and 1978 was barred
under the 10-year statute of limitations. The record is not
clear as to whether petitioners received a discharge in
bankruptcy; however, both parties stipulated that, sometime
during 1990, petitioners’ bankruptcy proceeding was “no longer
pending”.
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Last modified: May 25, 2011