Robert William Woods - Page 23

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               Petitioner has neither alleged nor presented any evidence              
          that any of the property to which the Federal tax lien attached             
          or upon which respondent intends to levy is exempt under section            
          6334(a).  Accordingly, we hold that respondent may proceed with             
          the proposed levy in satisfaction of petitioner’s tax liabilities           
          for the 1988, 1989, 1990, 1991, 1993, 1995, 1996 and 1997 taxable           
          years.                                                                      
          VI.  Petitioner’s Other Contentions.                                        
               Petitioner contends, in his brief, that respondent does not            
          have a claim because respondent failed to attend the creditors’             
          meeting on May 27, 2004, to object to petitioner’s discharge.               
          Petitioner’s argument has no merit.  Because the tax debts for              
          1996 and 1997 in the instant case are of the type specified in 11           
          U.S.C. sec. 523(a)(1), respondent was not required to object or             
          even file a claim to protect against discharge because the                  
          liabilities were nondischargeable.  Swanson v. Commissioner, 121            
          T.C. at 128.  Furthermore, the Federal tax liens are not                    
          extinguished by bankruptcy.  11 U.S.C. sec. 522(c)(2)(B).  A                
          discharge in bankruptcy extinguishes only the ability to proceed            
          against the debtor personally; it leaves intact the lien on the             
          debtor’s property.  Iannone v. Commissioner, supra at 293.                  
          Accordingly, because there were valid Federal tax liens on                  
          petitioner’s property for the 1988, 1989, 1990, 1991, 1993, and             
          1995 taxable years, it was not necessary for respondent to attend           






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