Alphonse Mourad - Page 13

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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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