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In Washington and Swanson we decided that the bankruptcy
court had not addressed whether the taxpayers’ tax debts were
discharged because the records in both cases lacked any evidence
to the contrary. The bankruptcy court orders in both Washington
and Swanson released the taxpayers from all “dischargeable
debts.” See Washington v. Commissioner, supra at 116; Swanson v.
Commissioner, supra at 120. In the instant case, however, the
bankruptcy court’s order makes no reference to dischargeable
debts. That lack of reference, however, is of no consequence.
Section 727 of title 11 does not release a debtor from a debt
that is nondischargeable under the Bankruptcy Code. Thus, an
order discharging a debtor from all “dischargeable debts” is no
different, for present purposes, from an order granting the
debtor “a discharge under section 727 of title 11, United States
Code”.
Accordingly, based upon our holdings in Washington and
Swanson, we hold that, in the instant levy proceeding commenced
under section 6330(d)(1), the Court has jurisdiction to decide
whether the U.S. Bankruptcy Court for the Northern District of
Alabama discharged petitioner’s tax liabilities for the 1988,
1989, 1990, 1991, 1993, 1995, 1996, and 1997 taxable years.
III. Sections 507 and 523 of the Bankruptcy Code.
As noted above, petitioner contends that his tax liabilities
for the years in issue were discharged because they were not
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