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party contends that we lack jurisdiction to decide this issue.
However, we may question our jurisdiction sua sponte at any stage
of the proceedings. Moorhous v. Commissioner, 116 T.C. 263, 272
(2001); Neely v. Commissioner, 115 T.C. 287, 290 (2000); Smith
v. Commissioner, 96 T.C. 10, 13-14 (1991).
This is an income tax deficiency case. In a deficiency
case, we lack jurisdiction to decide whether petitioner’s tax
liability was discharged in bankruptcy. Moody v. Commissioner,
95 T.C. 655, 658 (1990); Neilson v. Commissioner, 94 T.C. at 8-9;
Graham v. Commissioner, 75 T.C. 389, 399 (1980); Swanson v.
Commissioner, 65 T.C. 1180, 1184 (1976); Fotochrome, Inc. v.
Commissioner, 57 T.C. 842, 847 (1972). Thus, we will deny
petitioner’s motion to dismiss on the grounds that his 1993
liability for income tax and additions to tax was discharged in
bankruptcy. We do, however, have jurisdiction to redetermine the
deficiencies and additions to tax that respondent determined in
this case. Neilson v. Commissioner, supra at 6-8; Graham v.
Commissioner, supra at 398-399.
date of the filing of the petition; or
(iii) other than a tax of a kind
specified in section 523(a)(1)(B) or
523(a)(1)(C) of this title, not assessed
before, but assessable, under applicable
law or by agreement, after, the
commencement of the case;
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