Harvey M. Pert, Transferee - Page 47

                                       - 47 -                                         

          is a stay in effect.  Our opinion here does not interfere with              
          the exercise of the jurisdiction of the bankruptcy court.                   
               We need not and should not act to implement the bankruptcy             
          court's order.  We have no jurisdiction to decide whether Mrs.              
          Pert's liability as a taxpayer or transferee has been discharged            
          in bankruptcy.  See Neilson v. Commissioner, 94 T.C. 1, 8-9                 
          (1990).                                                                     
               To reflect concessions and the foregoing,                              


                                                            An appropriate            
                                                  Order will be issued and            
                                                  decisions will be                   
                                                  entered under Rule 155.             

Page:  Previous  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  43  44  45  46  47