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Management, the statements respondent’s representative made
during the bankruptcy confirmation hearing did not refer to, and
had no effect on, petitioner’s income tax liability for the year
at issue. Accordingly, we hold that respondent did not waive his
claim that petitioner owes income tax for 1997.
D. Conclusion
The filing of a bankruptcy petition does not terminate V&M
Management’s S corporation election, and the income of V&M
Management is taxable to petitioner. Petitioner is not entitled
to low-income housing tax credits for 1997, and respondent did
not waive any claim that petitioner is liable for income tax for
the year 1997.
Decision will be entered for
respondent.
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