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abuse of discretion or a de novo standard of review. Petitioner
bears the burden of proof. See Rule 142(a).
In her petition, petitioner appears to argue that respondent
erred in determining that the Federal tax liens for petitioner’s
1997 and 1998 income tax liabilities were valid at the time they
were filed. During petitioner’s section 6330 hearing,
petitioner’s counsel advised respondent that “[we] do not
disagree that the above mentioned [sic] liens are valid liens”.
Moreover, at trial, petitioner failed to introduce any evidence
or raise any specific argument supporting her contention that the
Federal tax liens were invalid as filed. We conclude that
petitioner has abandoned that issue. Petzoldt v. Commissioner,
92 T.C. 661, 683-687 (1989).
Petitioner further contends that respondent erroneously
determined that the Federal tax liens continued to be valid
against petitioner’s interest in her IRA after her discharge from
personal liability on the 1997 and 1998 income tax liabilities in
her chapter 7 bankruptcy case. We have specifically held that a
discharge from personal liability in a chapter 7 bankruptcy case
does not extinguish a prepetition Federal tax lien. Iannone v.
Commissioner, 122 T.C. 287 (2004); see also 11 U.S.C. sec.
522(c)(2)(B) (providing that exempt property remains subject to
properly filed tax liens even though the underlying tax claim may
have been discharged); Connor v. United States, 27 F.3d 365, 366
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