Neal Swanson - Page 1

                                   121 T.C. No. 7                                     

                               UNITED STATES TAX COURT                                

                             NEAL SWANSON, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6440-01L.            Filed August 28, 2003.                 

                    P did not file Federal income tax returns for the                 
               years 1993, 1994, and 1995.  R subsequently prepared                   
               substitutes for return (SFRs) for P and issued a notice                
               of deficiency to P based on the SFRs covering these                    
               years.  P filed a petition to this Court, but P’s case                 
               was later dismissed, and a decision was entered for R                  
               because P failed to state a claim upon which relief                    
               could be granted.  R assessed the tax liabilities for                  
               the years 1993, 1994, and 1995.  P subsequently filed a                
               petition under ch. 7 of the U.S. Bankruptcy Code.  The                 
               bankruptcy court entered an order generally releasing P                
               from all dischargeable debts.  The bankruptcy court did                
               not expressly determine whether P’s unpaid tax                         
               liabilities were discharged.  R issued a notice of                     
               intent to levy, and P requested a hearing before an IRS                
               Appeals officer (A) pursuant to sec. 6330, I.R.C.  At                  
               the hearing, P claimed that his unpaid liabilities were                
               discharged in bankruptcy.  A issued a notice of                        
               determination sustaining the levy, and P timely                        
               petitioned the Court for review.                                       

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