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tax liabilities. The sole issue for decision is whether
respondent may proceed with collection of the above-mentioned
unpaid income tax liabilities.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in California.
Petitioner’s Chapter 7 Bankruptcy Case
On September 30, 1993, petitioner and his wife filed a
petition under chapter 13 of the Bankruptcy Code in the U.S.
Bankruptcy Court for the Southern District of California (1993
bankruptcy case). On March 18, 1998, petitioner’s 1993
bankruptcy case was converted to a chapter 7 case. On July 12,
1998, the Bankruptcy Court entered a discharge order in
petitioner’s 1993 bankruptcy case.
Petitioner’s 1994, 1995, and 1996 Income Tax Returns
On February 15, 1998, petitioner and his wife filed
delinquent joint income tax returns for 1994, 1995, and 1996,
reporting $5,908.36, $7,416, and $2,171 of tax due, respectively.
Petitioner and his wife did not make any payments with the
returns, and the returns did not claim any prepayment credits.2
2 Petitioner and his wife claimed, and respondent allowed,
an earned income credit of $1,726 for 1996.
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