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the taxes, interest, and penalties for other taxable years of
petitioner, including 1991.
The record also establishes, although petitioner disputes,
that the Service received petitioner's return for 1991 on October
23, 1992.2
Respondent represents in respondent's motion, and petitioner
concedes and/or does not dispute, that respondent did not issue
to petitioner a notice of deficiency for 1995 and that counsel
for respondent notified the Service's revenue officer to cease
collection of any tax liabilities of petitioner for his taxable
years 1991 and 1995 pending a ruling by this Court on respon-
dent's motion.
Discussion
With respect to petitioner's taxable year 1991, although the
1991 notice was timely mailed to petitioner on October 19, 1995,
11 U.S.C. sec. 362(a)(8) (1994) imposed an automatic stay on
proceedings in this (and any other) Court during the pendency of
petitioner's bankruptcy case that he commenced on December 15,
1994. On May 3, 1996, the date on which the Bankruptcy Court
discharged petitioner, that automatic stay was lifted, even
though petitioner thereafter filed a motion to vacate the dis-
charge order. See Olson v. Commissioner, 86 T.C. 1314 (1986).
2 Petitioner contends that the Service received his 1991 return
on Oct. 20, 1992. Even if that contention were accurate, it
would have no effect on our conclusion regarding petitioner's
taxable year 1991.
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