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Federal income tax defi

determine whether a ban

  • -

    17 -

ciencies, we do not have jurisdiction to

kruptcy court has discharged a taxpayer

from an unpaid tax liab

ility.

Neilson

v.

Commissioner,

supra

at

9; Graham v. Commission

er, 75 T.C. 389, 399 (1980); Bilski v.

Commissioner, T.C. Memo

. 1994-55; McAlister v. Commissioner, T.C.

Memo. 1993-166.

8

II.

Capital

Gain

in

19

94 on the Sale of New Jersey House

Respondent determi

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

taxable year.”

Washington v.

114, 120 (2003).

Thus, this

or

has sec.

levy

proceeding

commenced

Court under

6330(d)(1)

to

determine

whether

a

bankruptcy

court

has

discharged

the taxpayer from Commissioner, 121 supra.

unpaid tax liabilities.

Swanson v.

T.C.

111

(2003);

Washington

v.

Commissioner,

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