Timothy S. Brumlik - Page 7

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          rendered the decision of the Bankruptcy Court final for                     
          essentially all purposes.  McQuade v. Commissioner, 84 T.C. 137,            
          140 (1985).                                                                 
               Once the order of the Bankruptcy Court becomes final with              
          respect to respondent's tax claims, generally neither the amount,           
          nor the validity of the Bankruptcy Court's order is subject to              
          review or reconsideration by this Court, McQuade v. Commissioner,           
          supra at 145.                                                               
               Accordingly, the doctrine of res judicata is controlling in            
          the instant cases, and respondent's motions for summary judgment            
          will be granted.                                                            
               To reflect the foregoing,                                              
                                             Appropriate orders                       
          and decisions will be                                                       
          entered granting                                                            
          respondent's motions for                                                    
          summary judgment.                                                           


                                                                                     














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