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WELLS, C.J., concurring: I respectfully concur in this
Court's decision to exercise jurisdiction in the instant case to
decide whether a tax liability has been discharged in bankruptcy.
I write to note, however, that our opinion does not necessarily
preclude taxpayers from seeking review in an appropriate Bank-
ruptcy Court after they have petitioned this Court. Although the
issue to be decided in the instant case is relatively straight-
forward, it is possible that taxpayers will present this Court
with more difficult questions that may be better suited for
consideration by a Bankruptcy Court. Under such circumstances,
this Court may defer to a Bankruptcy Court to decide the matter.
Such deference would not be premised upon any concerns that we
lack jurisdictional capacity to consider the issue. Rather, it
would be based upon considerations of comity and judicial effi-
ciency, combined with our recognition that this Court does not
deal with bankruptcy matters with the expertise that a Bankruptcy
Court possesses. See Kluger v. Commissioner, 83 T.C. 309, 320
(1984).
GERBER, BEGHE, and FOLEY, JJ., agree with this concurring
opinion.
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