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    16 -

dated

February

6,

1995,

and

closed

the

case

on

May

18,

1995.

The

order confirming the plan specifically discharged petitioner and

Mrs.

Wood.

Therefore,

the

automatic

stay

of

Bankruptcy

Code

section 362 was lifted no later than May 18, 1995, when the order

closing the case was entered.

Respondent issued to petitioner and Mrs. Wood a notice of

deficiency for 1994 on December 21, 1998, and a notice of

deficiency

for

1995

and

1996

on

July

19,

1999.

Thus,

the

notices

of deficiency were issued, and the petitions in these cases were

filed, well after the automatic stay in petitioner and Mrs.

Wood’s bankruptcy case was lifted.

Petitioner contends, and asks us to rule, that respondent’s

claims

against

him

were

discharged

in

bankruptcy.

We

do

not

have

authority in these cases to decide whether respondent’s claims

against petitioner have been discharged because in a deficiency

proceeding our subject matter jurisdiction is generally limited

to the redetermination of the correct amount of a deficiency

determined by the Commissioner and is unrelated to the collection

of

the

tax.

Swanson

v.

Commissioner,

65

T.C.

1180,

1184

(1976).

An action brought for redetermination of a deficiency “has

nothing to do with collection of the tax nor any similarity to an

action

for

collection

of

a

debt”.

Id.

Thus,

in

deficiency

proceedings commenced in this Court under section 6213, such as

these cases, while we have jurisdiction to redetermine the

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