Leonard O. Parker, Jr. - Page 1

                         T.C. Memo. 2006-117                                          

                               UNITED STATES TAX COURT                                

                        LEONARD O. PARKER, JR., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     

               Docket No. 4053-03L.     Filed June 8, 2006.                           

                    P filed a Motion for Reconsideration and a Motion                 
               to Vacate challenging some of the Court’s factual and                  
               legal conclusions.                                                     
                    P asserts that this Court erred by not finding R                  
               violated the automatic bankruptcy stay imposed under 11                
               U.S.C. sec. 362(a) (1994), when R assessed P’s tax                     
               liability for 1994 before the stay was lifted.                         
                    Held: The Government’s claim for P’s 1994 tax                     
               liability arose no earlier than Dec. 31, 1994, and                     
               therefore postdated the commencement of the case in                    
               bankruptcy on April 7, 1994.  Thus, the bankruptcy stay                
               did not bar the assessment of P’s 1994 income tax                      

               * This Supplemental Memorandum Opinion supplements our prior           
          opinion in Parker v. Commissioner, T.C. Memo. 2006-43.                      

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