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bankruptcy trustee was still actively pursuing claims beyond that
date.
We reject petitioners' expansive reading of section
108(a)(1)(A) and (d)(2) which is contrary to the fundamental
principle of statutory construction that where a statute is clear
on its face, unequivocal evidence of legislative purpose is
required to override the plain meaning of the words used.
Huntsberry v. Commissioner, 83 T.C. 742, 747-748 (1984).
The language in section 108(d)(2) is fairly explicit. It
provides that a "title 11 case" means a case under title 11 (the
bankruptcy code), but only if the taxpayer is under the
jurisdiction of the bankruptcy court and the discharge of
indebtedness is "granted by the court or is pursuant to a plan
approved by the court". Sec. 108(d)(2). Consequently, we read
the statute to contemplate that, in general, in a title 11 case,
the bankruptcy court must grant the discharge either in a
specific order, or as part of a plan approved by the court
itself.
We observe that the bankruptcy trustee was active in
conducting New Manchester's business as well as disbursing
amounts to creditors after the 1992 taxable year. In that vein,
the trustee periodically filed reports with the bankruptcy court
on the status of the foregoing proceedings. Certain creditors
filed a fraudulent conveyance claim against petitioners on
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