James E. And Elizabeth Tatum v. Commissioner of Internal Revenue

GARZA, Circuit Judge:

Petitioner, Mr. Tatum, appeals a decision of the Tax Court dismissing his case for lack of jurisdiction. In an opinion reported at 69 T.C. 81, the Tax Court interpreted the provisions of Section 2a(2A) of the Bankruptcy Act, 11 U.S.C. § ll(a)(2A), 1 and Section 17c of the Bankruptcy Act, 11 U.S.C. § 35(c)(1), 2 as vesting complete jurisdiction in the Bankruptcy Court concerning additions to tax determined under Sections 6651(a) and 6653(a) of the Internal Revenue Code of 1954 and therefore concluded that they lacked jurisdiction to determine the correctness of these…