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petition) in the U.S. Bankruptcy Court for the Southern District
of New York, thereby commencing a bankruptcy proceeding under
Chapter 7 of Title 11 of the United States Code. Attached to
petitioners’ bankruptcy petition was a document entitled “Sched-
ule E - Creditors Holding Unsecured Priority Claims” (petition-
ers’ bankruptcy Schedule E). Petitioners’ bankruptcy Schedule E
listed the Internal Revenue Service as a creditor with respect to
a claim totaling $20,000 relating to petitioners’ “TAXES FOR
1991, 1992, 1993, 1994, 1995, & 1996.”5
On September 25, 1998, the U.S. Bankruptcy Court for the
Southern District of New York entered a “DISCHARGE OF DEBTOR,
ORDER OF FINAL DECREE” (September 25, 1998 discharge order). The
September 25, 1998 discharge order provided in pertinent part:
IT IS ORDERED THAT:
1. The Debtor is released from all dischargeable
debts.
2. Any judgment not obtained in this court is null and
void as to the personal liability of the Debtor(s)
regarding the following:
4(...continued)
Court for the Southern District of New York stamped on that
petition, and we shall disregard that stipulation. See Cal-Maine
Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989). The record
establishes, and we have found, that petitioners filed their
bankruptcy petition on May 18, 1998.
5The only other creditor listed in petitioners’ bankruptcy
Schedule E was the New York State Department of Taxation and
Finance with respect to a claim totaling $7,000 relating to
petitioners’ “TAXES FOR 1991, 1992, 1993, 1994, 1995 & 1996.”
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