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County Recorder’s office with respect to petitioner and Mr.
Romine’s 1997 income tax liability.
Petitioner and Mr. Romine filed a joint Federal income tax
return for 1998 (the 1998 return) reporting tax due of $77,733
and withholding tax credits of $24,915. No payment accompanied
that return.3
On June 7, 1999, respondent assessed the tax reported on the
1998 return, interest, and additions to tax. On July 3, 2000,
respondent assessed additional tax of $54,368 pursuant to an
agreement executed by petitioner, Mr. Romine, and respondent.
On October 19, 1999, respondent filed an NFTL with the San Diego
County Recorder’s office with respect to petitioner and Mr.
Romine’s 1998 income tax liability.
Petitioner’s Bankruptcy Proceedings
On May 19, 2003, petitioner filed a petition pursuant to
chapter 7 of the U.S. Bankruptcy Code in the U.S. Bankruptcy
Court for the Southern District of California (the Bankruptcy
Court). In connection with her bankruptcy case, petitioner filed
a complaint to determine the dischargeability of her Federal
income tax liabilities for the tax years 1996, 1997, and 1998.
On July 22, 2003, the Bankruptcy Court entered a stipulation for
entry of judgment and judgment thereon in which the Bankruptcy
3 A payment of $741.48 was made toward the 1998 liability
on May 24, 2002.
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