John Weller Wood, Jr., and Magdalena Frances Wood - Page 16

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          dated February 6, 1995, and closed the case on May 18, 1995.  The           
          order confirming the plan specifically discharged petitioner and            
          Mrs. Wood.  Therefore, the automatic stay of Bankruptcy Code                
          section 362 was lifted no later than May 18, 1995, when the order           
          closing the case was entered.                                               
               Respondent issued to petitioner and Mrs. Wood a notice of              
          deficiency for 1994 on December 21, 1998, and a notice of                   
          deficiency for 1995 and 1996 on July 19, 1999.  Thus, the notices           
          of deficiency were issued, and the petitions in these cases were            
          filed, well after the automatic stay in petitioner and Mrs.                 
          Wood’s bankruptcy case was lifted.                                          
               Petitioner contends, and asks us to rule, that respondent’s            
          claims against him were discharged in bankruptcy.  We do not have           
          authority in these cases to decide whether respondent’s claims              
          against petitioner have been discharged because in a deficiency             
          proceeding our subject matter jurisdiction is generally limited             
          to the redetermination of the correct amount of a deficiency                
          determined by the Commissioner and is unrelated to the collection           
          of the tax.  Swanson v. Commissioner, 65 T.C. 1180, 1184 (1976).            
          An action brought for redetermination of a deficiency “has                  
          nothing to do with collection of the tax nor any similarity to an           
          action for collection of a debt”.  Id.  Thus, in deficiency                 
          proceedings commenced in this Court under section 6213, such as             
          these cases, while we have jurisdiction to redetermine the                  






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