Taxes in assessments issued in 2019 were not subject to a bankruptcy discharge order where the taxpayer had filed the bankruptcy petition in 2016. The issuance of assessments is not an action to collect a debt, but rather an act to determine liability. Whether some or part of the tax assessed is affected by a bankruptcy filing is a different question from whether the issuance of an assessment is valid.
Automatic stay after taxpayer's bankruptcy petition did not apply. The issuance of assessments is not an action to collect a debt against either the debtor taxpayer or a bankruptcy estate, but rather an act to determine liability.
Combined reporting of overall net income by parent company and its unitary affiliates was necessary where parent designed and developed programs for implementation by its affiliates and directed the affiliates' day-to-day operations.
Taxpayer did not use its investment account in its regular trade or business so its investment income was not business income. Reimbursement of shared business expenses from a co-tenant was business income.