Melvin Ray Hassell - Page 2

                                        - 2 -                                         
          motion.                                                                     
                                     Background                                       
               The record establishes and/or the parties do not dispute the           
          following.                                                                  
               Petitioner Melvin Ray Hassell (petitioner or Mr. Hassell)              
          resided in Irving, Texas, at the time he filed the petition in              
          this case.                                                                  
               On November 23, 1981, February 7, 1983, February 27, 1984,             
          March 25, 1985, and December 9, 1985, petitioner and Nelda                  
          Hassell (Ms. Hassell) jointly filed Form 1040, U.S. Individual              
          Income Tax Return (Form 1040), for each of their taxable years              
          1980, 1981, 1982, 1983, and 1984.2                                          
               Respondent issued a notice of deficiency to petitioner with            
          respect to his taxable years 1980 through 1984.  Petitioner filed           
          a petition with the Court with respect to that notice.  (We shall           
          refer to the case at docket No. 19885-89 that petitioner com-               
          menced when he filed the petition with respect to his taxable               
          years 1980 through 1984 as petitioner’s Tax Court case.)                    
               On September 20, 1990, the Court entered a decision in                 
          petitioner’s Tax Court case.  That decision provided:                       
                    Pursuant to agreement of the parties in this case,                
               it is                                                                  

               2This case involves only petitioner, and not Ms. Hassell.              
          For convenience, hereinafter we shall sometimes refer only to               
          petitioner or Mr. Hassell, and not to petitioner or Mr. Hassell             
          and Ms. Hassell.                                                            





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