Lisa Susan Kovitch, Petitioner, and Richard P. Kovitch, Intervenor - Page 10




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          that the automatic stay imposed by 11 U.S.C. section 362(a)(8)              
          does not preclude this Court from proceeding in this case to                
          determine whether petitioner is entitled to relief, nor does it             
          prohibit Mr. Kovitch from participating as an intervenor in this            
          case.                                                                       
               To reflect the foregoing,                                              
                                                  An appropriate order will           
                                             be issued.                               




















               9(...continued)                                                        
          Kovitch in the future.  For example, if petitioner’s request for            
          relief were denied, respondent might collect the joint liability            
          from petitioner as opposed to Mr. Kovitch.  We do not believe               
          that such speculative possibilities are sufficient to make this a           
          proceeding concerning the tax liability of the debtor in                    
          bankruptcy.  Our decision in this case will not alter Mr.                   
          Kovitch’s tax liability.                                                    






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