§157

Based on the language of the statutory provisions and the legislative history of those provisions, we hold that petitioner’s use of the [cash] distributions from his Keogh and IRA’s [sic] to purchase stock which he then contributed to the Smith Barney IRA does not constitute a tax-free rollover contribution under section 402(c) or 408(d)(3), respectively.

157(b)(1), (2)(B); 11 U.S.C. sec. 502(b) (2018). Ifa creditor files a "proofofclaim", it is deemed allowed unless a party in interest objects, in which case the bankruptcy court then determines the amount ofthe claim. 11 U.S.C. sec. 502. In general, the confirmation ofa bankruptcy plan "discharges the debtor from any debt that arose before the

157(h)(2), 92 Stat. at 2808. - 15 - [*15] subject to the limitation in section 408(d)(3)(B) and is includible in petitioners' gross income. Whether a distribution qualifies for rollover treatment under section 408(d)(3)(A) can be determined only by reference to the 60-day period within which a taxpayermust repay the distribution to an eligibl

157(a)) over all but certain specified bankruptcy discharge issues. - 30 - years would be inappropriate, and therefore respondent could not proceed. In any event, a challenge to the appropriateness of collection action under section 6330(c)(2)(A)(ii) is illustrative of the type of “any relevant issue relating to the unpaid tax” the taxpayer m

157(f)(1), 92 Stat. 2763, 2806. This exception permitted property distributed to be sold and the proceeds contributed during the 60-day period. The narrow scope of this section is reflected in Staff of Joint Comm. on Taxation, General Explanation of the Revenue Act of 1978, Pub. L. 95-600, at 110 (J. Comm. Print 1979). See also Rev. Rul. 87- 7

9 (1989): The circumstances of this case do not warrant withholding relief from a mistake. The mere fact that the party seeking relief did not exercise reasonable care does not preclude reformation. 1 Restatement, Contracts 2d, sec. 155, comment a; sec. 157, p. 416. Reformation provides a result that both parties agreed to and prevents an unintended and unexpected windfall. * * * We now turn to the proper computation of interest, for purposes of determining whether or not petitioner has actually

9 (1989): The circumstances of this case do not warrant withholding relief from a mistake. The mere fact that the party seeking relief did not exercise reasonable care does not preclude reformation. 1 Restatement, Contracts 2d, sec. 155, comment a; sec. 157, p. 416. Reformation provides a result that both parties agreed to and prevents an unintended and unexpected windfall. * * * We now turn to the proper computation of interest, for purposes of determining whether or not petitioner has actually

157H(2), Companies Ordinance of Hong Kong. Although petitioner does not include the deposit of Multi-Credit that was pledged to secure the UB $800,000 Radcliffe loan in his assertion, Union Bank's security interest in that deposit also was probably unenforceable for the same reason, i.e., petition- er's admission that the pledge of that deposi