Federal income tax defi
determine whether a ban
ciencies, we do not have jurisdiction to
kruptcy court has discharged a taxpayer
from an unpaid tax liab
9; Graham v. Commission
er, 75 T.C. 389, 399 (1980); Bilski v.
Commissioner, T.C. Memo
. 1994-55; McAlister v. Commissioner, T.C.
94 on the Sale of New Jersey House
ned that petitioner’s corrected capital
gain on the sale of the
New Jersey house was not $76,771 (as
reported on petitioner’
s 1994) return but rather $90,888,
computed as follows:
8In contrast to a deficiency proceeding, a lien proceeding commenced in this Court under sec. 6330(d)(1) “is closely related
to and has everything to do with collection of a taxpayer’s
unpaid liability for a Commissioner, 120 T.C. jurisdiction in a lien
114, 120 (2003).
the taxpayer from Commissioner, 121 supra.
unpaid tax liabilities.