- 22 - 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 ofPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011