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    15 -

filing a timely petition with this Co

urt is suspended for the

period during which the taxpayer is p

rohibited by reason of the

automatic stay from filing a petition

in this Court and for 60

days

thereafter.

Sec.

6213(f);

Olson

v. Commissioner, 86 T.C.

1314, 1318-1319 (1986).

Unless relief from the automatic

stay is granted by order of

the bankruptcy court, the automatic s

tay generally remains in

effect until the earliest of the clos

ing of the case, dismissal

of the case, or the grant or denial o

f

a

discharge.

7

11

U.S.C.

sec. 362(c)(2); Guerra v. Commissione

r, 110 T.C. 271, 275 (1998);

Allison v. Commissioner, supra at 545

; Smith v. Commissioner, 96

T.C. 10, 14 (1991); Neilson v. Commis

sioner, 94 T.C. 1, 8 (1990).

Petitioner filed for bankruptcy

on

April

29,

1994.

The

bankruptcy court confirmed the plan o

f reorganization by order

7The period that prescribed in 11 U.S.

the automatic stay remains in effect is C. sec. 362(c) as follows:

(c) Except as pr of this section-

ovided in subsections (d), -

(e), and (f)

(1) the stay of under subsection such property is

an act against property of the estate (a) of this section continues until no longer property of the estate; and

(2) the stay of this section con

  • (A)

    the time the

  • (B)

    the time the

  • (C)

    if the case

concerning an in 12, or 13 of thi granted or denie

any other act under subsection (a) of tinues until the earliest of--

case is closed; case is dismissed; or is a case under chapter 7 of this title dividual or a case under chapter 9, 11, s title, the time a discharge is d.

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