Oliver W. and Edna D. Wilson - Page 22




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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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