OPINION
GERBER, Judge:
In the setting of a motion for partial summary judgment, we consider whether respondent is collaterally estopped from determining income tax deficiencies for the same taxable years in amounts that exceed respondent's tax claims in petitioners' confirmed reorganization under chapter 11 of the Bankruptcy Code. We also consider petitioners' claim that we lack jurisdiction to consider the income tax deficiencies because of the bankruptcy...
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