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petition. The tax, therefore, is not dischargeable under Federal
law.
Petitioners also contend that, after their bankruptcy
discharge, the bankruptcy proceeding was reopened in order to
allow into the bankruptcy estate a monetary judgment of $607,500
petitioners recovered against a former employer. Because of this
reopening of the bankruptcy proceeding, petitioners contend that
a new "stay" came into effect. The Court rejects that argument
because no evidence was presented to show that the stay was
reinstituted by the bankruptcy court. See Guerra v.
Commissioner, 110 T.C. 271, 277-278 (1998). The reopening of the
bankruptcy proceeding is not a restoration of the stay against
this Court.
The Court holds that petitioners are liable for the
additional tax under section 72(t). Respondent is sustained on
this issue.
The second issue is whether petitioners are liable for the
accuracy-related penalty under section 6662(a) for negligence or
disregard of rules or regulations. Section 6662(a) provides
that, if it is applicable to any portion of an underpayment in
taxes, there shall be added to the tax an amount equal to 20
percent of the portion of the underpayment to which section 6662
applies. Section 6662(b)(1) provides that section 6662 shall
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