Timothy S. Brumlik - Page 3

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          was subsequently transferred to the U.S. Bankruptcy Court for the           
          Middle District of Florida (the Bankruptcy Court).                          
               On August 14, 1991, respondent filed in petitioners'                   
          bankruptcy proceeding a proof of claim and on August 23, 1991,              
          respondent filed an amended proof of claim on behalf of the                 
          United States reflecting respondent's determination of                      
          petitioners' Federal income tax liabilities for the years in                
          issue.3  Respondent notified this Court of the bankruptcy                   
          proceedings, and pursuant to 11 U.S.C. sec. 362(a)(8)(1994)                 
          (Bankruptcy Code), this Court on May 17, 1991, stayed all                   
          proceedings in these cases (the automatic stay).                            
               On November 13, 1991, petitioners filed with the Bankruptcy            
          Court an objection to respondent's proof of claim and a complaint           
          for an adversary hearing regarding respondent's proof of claim.             
          On January 31, 1992, a chapter 11 trustee (the trustee) was                 
          appointed to replace petitioners as the debtor-in-possession.  On           
          July 7, 1992, the Bankruptcy Court held an adversarial hearing              
          (the hearing), inter alia, on petitioners' objection to                     
          respondent's proof of claim.  On July 23, 1992, at the conclusion           
          the hearing, the Bankruptcy Court announced its oral findings.              
          On May 7, 1993, based on the evidence submitted to the Bankruptcy           
          Court at the July 7, 1992, hearing, the Bankruptcy Court entered            

          3    The proof of claim filed by respondent included the taxable            
          years 1985 through 1988, which are the years in issue in the                
          instant cases, as well as 1984, 1989, and 1990, which years are             
          not before this Court.                                                      




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