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CCH (cch.taxgroup.com) reports:

A married couple's outstanding federal income taxes were not discharged by a bankruptcy discharge order. The taxes related to a tax year that was within the three-year lookback period immediately before the filing of the bankruptcy petition. Moreover, Code Sec. 6503(h), not Code Sec. 6503(b), controlled and suspended the running of the collection period of limitations from the date the couple's bankruptcy petition was filed to a date six months after the bankruptcy court issued its order of discharge. Accordingly, the period of limitations for collecting the couple's outstanding federal income taxes had not expired at the time the couple requested an Appeals Office hearing. Finally, the Tax Court lacked jurisdiction over the IRS's decision letter relating to its notice of intent to make a second levy because the Tax Court cannot review IRS decision letters relating to equivalent hearings.
M.V. Severo, 129 TC No. 17, Dec. 57,173
Other References:
Code Sec. 6323
CCH Reference - 2007FED ¶38,160.87
Code Sec. 6330
CCH Reference - 2007FED ¶38,184.50
Code Sec. 6503
CCH Reference - 2007FED ¶39,032.16
Tax Research Consultant
CCH Reference - TRC IRS: 51,056
CCH Reference - TRC IRS: 57,054