Oren G. Bigelow Debra G. Bigelow, Deceased and Pamela E. Bigelow v. Commissioner of Internal Revenue

The Bigelows timely appeal from a decision of the Tax Court. They argue that the Tax Court’s ruling is void because it violated the automatic stay that took effect upon filing of their bankruptcy petition. The Tax Court had jurisdiction under 26 U.S.C. §§ 6213, 6214, and 7442. We have jurisdiction pursuant to 26 U.S.C. § 7482. We affirm.

BACKGROUND

During 1981 and 1982, the IRS issued roughly 300 notices of deficiency to participants in a tax shelter. The recipients of these notices of deficiency responded with Tax Court petitions challenging the IRS’ dis-allowance of the deductions. The…