brief submitted in support of the government’s motion for summary judgment below. See Defendant’s Answer ¶ 24; Defendant’s Memorandum in Opposition to Plaintiffs Motion for Summary Judgment and in Support of Defense Cross-Motion (“Def.’s Memo Below”) at 31. While the Bankruptcy Court did not address the statute of limitations issue created by § 6532(a), this actually presents a jurisdictional question as to whether the Bankruptcy Court properly exercised its jurisdiction for the 1984 and 1985 tax years. See Finkelstein v. United States, 943 F.Supp. 425, 431 (D.N.J.1996). This Court must consider the application of the statute of limitations contained in § 6532(a) to the debtor’s adversary proceeding below. See Becton Dickinson and Co. v. Wolckenhauer, 215 F.3d 340, 343 (3d Cir.2000) (<HOLDING>). Pransky filed tax returns for the 1984
holding that a reviewing court has the power to reject the findings and conclusions of the trial court where the findings are not supported by the evidence holding that reviewing court may consider trial evidence in reviewing denial of motion to suppress holding that the court had discretion to allow substitution of plaintiffs to satisfy diversity jurisdiction requirements in order to give the court jurisdiction where no jurisdiction existed when the complaint was filed holding that a reviewing court will not address those issues not raised below or not addressed by the trial court holding that a reviewing court has an obligation to satisfy itself of the jurisdiction of the court below