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not deprive this Court of subject matter jurisdiction in a
proceeding filed by the taxpayer in this Court.
OPINION
I. Preliminary Matters
Petitioners filed an opening brief and a supplemental brief
in this case. Petitioners’ arguments in both briefs focused
almost exclusively on the effect of petitioners’ various
bankruptcy proceedings on this Court’s jurisdiction and on this
Court’s ability to dispose of the substantive issues raised at
trial and in respondent’s trial briefs. Petitioners also filed a
posttrial motion to dismiss, raising the same jurisdictional
issue discussed in their posttrial briefs.
As best we understand them, the procedural issues raised in
petitioners’ posttrial briefs and/or in the motion to dismiss
were as follows:
(1) Whether this Court has the requisite jurisdiction to
adjudicate the issues involved in this case;
(2) whether the amounts at issue in this case were
discharged in petitioners’ bankruptcy proceedings; and
(3) whether the doctrine of res judicata applies to prevent
the adjudication of the issues involved in this case.
Upon consideration of petitioners’ motion to dismiss and
respondent’s objections to petitioners’ motion, we concluded
that petitioners’ bankruptcy proceedings did not deprive us of
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