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filing a timely petition with this Court is suspended for the
period during which the taxpayer is prohibited by reason of the
automatic stay from filing a petition in this Court and for 60
days thereafter. Sec. 6213(f); Olson v. Commissioner, 86 T.C.
1314, 1318-1319 (1986).
Unless relief from the automatic stay is granted by order of
the bankruptcy court, the automatic stay generally remains in
effect until the earliest of the closing of the case, dismissal
of the case, or the grant or denial of a discharge.7 11 U.S.C.
sec. 362(c)(2); Guerra v. Commissioner, 110 T.C. 271, 275 (1998);
Allison v. Commissioner, supra at 545; Smith v. Commissioner, 96
T.C. 10, 14 (1991); Neilson v. Commissioner, 94 T.C. 1, 8 (1990).
Petitioner filed for bankruptcy on April 29, 1994. The
bankruptcy court confirmed the plan of reorganization by order
7The period that the automatic stay remains in effect is
prescribed in 11 U.S.C. sec. 362(c) as follows:
(c) Except as provided in subsections (d), (e), and (f)
of this section--
(1) the stay of an act against property of the estate
under subsection (a) of this section continues until
such property is no longer property of the estate; and
(2) the stay of any other act under subsection (a) of
this section continues until the earliest of--
(A) the time the case is closed;
(B) the time the case is dismissed; or
(C) if the case is a case under chapter 7 of this title
concerning an individual or a case under chapter 9, 11,
12, or 13 of this title, the time a discharge is
granted or denied.
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