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taxable years 1990, 1991, 1992, 1993, and 1996. We hold that
respondent may proceed with collection.
FINDINGS OF FACT
At the time he filed the petition, petitioner resided in
Powhatan, Virginia.
Petitioner filed a Federal income tax return for 1990,
received by respondent on August 21, 1991, that reported tax due
of $2,988. Respondent assessed the reported tax, as well as
additions to tax under sections 6651(a)(1), 6651(a)(2), and 6654,
and interest (collectively, the 1990 liability). The 1990
liability was unpaid at the time of trial.
Petitioner filed a Federal income tax return for 1991,
received by respondent on June 7, 1993, that reported tax due of
$12,142. Respondent assessed the reported tax, as well as
additions to tax under sections 6651(a)(1), 6651(a)(2), and 6654,
and interest (collectively, the 1991 liability). The 1991
liability was unpaid at the time of trial.
On August 2, 1993, petitioner filed a Chapter 7 bankruptcy
petition, and was granted a discharge on November 15, 1993.
Petitioner filed a Federal income tax return for 1992,
received by respondent on June 10, 1994, that reported tax due of
$6,071. Petitioner had received an extension to file this return
until August 15, 1993. Respondent assessed the reported tax, as
well as additions to tax under sections 6651(a)(1), 6651(a)(2),
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