With no explanation, chose the best option from "A", "B", "C" or "D". something that it is not; following the Simmons line of cases, we require an objection to a proof of claim or a § 505 motion to determine the amount of a tax debt. This burden is minor and no greater than the filing of a tax return required of all taxpayers. Therefore, Taylor’s Plan is not res judicata as to the amount of his liability on the Marshall Mill § 6672 penalty, and the IRS is not barred from proceeding against him to collect that penalty. Taylor’s reliance upon the fact that the IRS filed a proof of claim for income taxes as support for his claim that res judicata should apply is misplaced. The § 6672 penalty is a completely separate debt and a separate type of tax which is not determined by the consideration of an income tax proof of claim. Cf. Grynberg, 986 F.2d at 371-72 (<HOLDING>). Therefore, the tax determination process was

A: holding that a decedents tax settlement with the irs did not establish the value of his estates claim against the irs as a matter of law
B: holding that the irss full participation in the bankruptcy proceeding in relation to an income tax debt did not bar it from collecting a gift tax debt that had also been listed in the debtors schedules where the irs did not file a proof of claim and the debtor did not force the irs into the proceeding on the gift tax debt
C: holding that  362 did not prevent the irs from collecting a postpetition debt by levying upon property of the debt or
D: holding that effect of discharge of debt under bankruptcy code is the same as it was under the 1898 bankruptcy act it is not an extinguishment of the debt but only a bar to enforcement of the debt as a personal obligation of the debt or
B.