Clara L. Prevo - Page 6

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          U.S.C. section 362(b)(9), to issue a notice of deficiency to a              
          taxpayer in bankruptcy.  See Kieu v. Commissioner, 105 T.C. 387,            
          391 (1995).  Even though, as previously discussed, such a                   
          taxpayer would be barred from filing a petition for                         
          redetermination with this Court so long as the automatic stay               
          remained in effect, Congress established a procedure to permit              
          such a taxpayer to invoke the Court’s deficiency jurisdiction               
          under section 6213(a) after the bankruptcy proceedings are                  
          completed.  Specifically, section 6213(f) provides that the                 
          statutory period for filing a timely petition with the Court                
          under section 6213(a) is suspended for the period during which              
          the taxpayer is prohibited by reason of the automatic stay from             
          filing a petition for redetermination and for 60 days thereafter.           
          See Olson v. Commissioner, 86 T.C. 1314, 1318-1319 (1986) (and              
          cases cited therein).  We observe that the benefits of section              
          6213(f) may apply whether a notice of deficiency is mailed before           
          or after the filing of a bankruptcy petition.  See McClamma v.              
          Commissioner, 76 T.C. 754 (1981).                                           
          Collection Review Procedures                                                
               Section 6321 imposes a lien in favor of the United States on           
          all property and rights to property of a person liable for taxes            
          when a demand for the payment of the person’s taxes has been made           
          and the person fails to pay those taxes.  Such a lien arises when           
          an assessment is made.  Sec. 6322.  Section 6323(a) requires the            






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