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suspended, and Mr. Beatty was placed on supervised probation for
five years. As a condition of his probation, Mr. Beatty was
required to file a Federal income tax return (Federal return) and
a State return for each of his taxable years 1995 through 1999.
Around September 7, 2000, petitioner and Mr. Beatty filed
jointly Form 1040, U.S. Individual Income Tax Return (Form 1040),
for each of their taxable years 1998 (1998 joint return) and 1999
(1999 joint return). In their 1998 joint return and their 1999
joint return, petitioner and Mr. Beatty reported tax owed of
$46,710 and $31,533, respectively, which they did not pay at the
time they filed those returns. The liabilities reported in those
returns (unpaid liabilities for 1998 and 1999) are solely attrib-
utable to Mr. Beatty.
On September 14, 2000, petitioner filed a petition for
bankruptcy (bankruptcy petition) under Chapter 7 of Title 11 of
the United States Code (Chapter 7) with the United States Bank-
ruptcy Court for the District of Maryland (Bankruptcy Court).
Petitioner filed the bankruptcy petition because of excessive
credit card debt that she was unable to pay and that had been
generated by Mr. Beatty, who used credit cards in petitioner’s
name to charge business expenses. On January 23, 2001, the
Bankruptcy Court adjudicated petitioner bankrupt under Chapter 7.
In 2001, on a date not disclosed by the record, the Comp-
troller of Maryland directed Mr. Beatty to file a Federal return
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