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Leonard O. Parker, Jr., pro se.
Hieu C. Nguyen, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
HAINES, Judge: On April 20, 2006, petitioner filed a Motion
for Reconsideration of Findings or Opinion under Rule 161, and a
Motion to Vacate or Revise a Decision under Rule 162
(collectively, the motions).1 Since the motions are identical,
they will be addressed together.
The Court incorporates herein its Findings of Fact in Parker
v. Commissioner, T.C. Memo. 2006-43. For convenience and
clarity, the Court repeats below the facts directly relevant to
the disposition of these motions.
Petitioner filed for bankruptcy under title 11 of the United
States Code on April 7, 1994. Petitioner subsequently filed his
1994 Federal income tax return on August 18, 1995, in which he
reported income of $8,123 for 1994 and tax due of $1,134. He
failed to pay the full amount due for 1994. Respondent assessed
petitioner’s 1994 Federal income tax liabilities on October 9,
1995. The bankruptcy case was dismissed on June 28, 1996.2
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. Amounts
are rounded to the nearest dollar.
2 Petitioner also filed for bankruptcy on two other
occasions: the proceeding filed on Nov. 26, 1997, was closed on
(continued...)
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