Gregory Iannone - Page 1

                                   122 T.C. No. 16                                    

                               UNITED STATES TAX COURT                                

                           GREGORY IANNONE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17412-02L.             Filed April 19, 2004.                

                    P filed a timely petition for judicial review                     
               pursuant to sec. 6330(d)(1)(A), I.R.C., in response to                 
               a notice of determination by R to proceed with                         
               collection of assessed tax liabilities for 1987, 1989,                 
               and 1991.  Subsequently, the Court granted respondent’s                
               Motion to Dismiss for Lack of Jurisdiction and to                      
               Strike as to Taxable Year 1987.                                        
                    Held:  For the purpose of this collection                         
               proceeding, the Appeals officer agreed to assume that                  
               petitioner’s 1989 and 1991 tax liabilities were                        
               discharged in bankruptcy.  We will not remand this case                
               for a clearer articulation of the Appeals officer’s                    
               determination relating to petitioner’s bankruptcy                      
                    Held, further, the existing Federal tax lien that                 
               attached to P’s property when he filed his bankruptcy                  

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