- 23 - jurisdiction over this case, Freytag v. Commissioner, supra at 41, and we denied petitioners’ motion. Although petitioners in their posttrial briefs again attempt to challenge this Court’s jurisdiction in this case, we reject petitioners’ jurisdictional argument. We also reject petitioners’ allegations that the tax liabilities at issue in this case were fully litigated in their bankruptcy proceeding and that the doctrine of res judicata operates to preclude additional litigation in this Court. The record is devoid of any evidence demonstrating that the subject tax liabilities were ever litigated in any of petitioners’ bankruptcy proceedings. In fact, the order of discharge relied upon by petitioners expressly states that the debts for most taxes are not discharged in a chapter 7 bankruptcy case and that any party to that case may request that it be reopened to determine whether a particular debt has been discharged. See Neilson v. Commissioner, 94 T.C. 1, 9 (1990) (Tax Court lacks jurisdiction to decide whether income tax deficiencies were discharged in bankruptcy). Moreover, petitioners have made no effort to explain how the elements of res judicata are satisfied by the record in this case. Consequently, we reject petitioners’ bankruptcy-related arguments, and we proceed to the substantive issues presented in this case.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011