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Allison v. Commissioner, 97 T.C. at 545. As of July 24, 1996, by
operation of section 6213(f), petitioner had a total of 150 days
to file a timely petition with the Court contesting the notices
of deficiency for 1989, 1990, and 1991. In particular,
petitioner enjoyed the 60-day suspension period prescribed in
section 6213(f), plus the normal 90-day filing period prescribed
in section 6213(a).
During the ensuing period, petitioner did not file a
petition for redetermination with the Court. Nonetheless, on
December 6, 1996, petitioner filed a bankruptcy petition under
chapter 7 of the Bankruptcy Code. As of December 6, 1996, 135
days had elapsed since July 24, 1996--the date that the
bankruptcy court dismissed petitioner's bankruptcy petition under
chapter 13, leaving petitioner with 15 days to file a timely
petition with the Court pursuant to section 6213(f). However, as
a result of the filing of petitioner's bankruptcy petition under
chapter 7, petitioner again was barred from filing a petition for
redetermination with the Court by virtue of the automatic stay
imposed under 11 U.S.C. section 362(a)(8). Further, the
remaining 15-day period that petitioner had for filing a timely
petition with the Court to contest the notices of deficiency for
1989, 1990, and 1991 was suspended pursuant to section 6213(f).
On April 7, 1997, the bankruptcy court entered an order of
discharge in petitioner's chapter 7 bankruptcy case, which served
to terminate the automatic stay imposed under 11 U.S.C. section
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