Skip to main content

§ 523(a)(1)(A)

Acuna, In re--Acuna v. Ill. Dep't of Revenue

Ruling
Debtor's unpaid income tax for a taxable year ending on or before the petition date and lastdue before the petition date was nondischargeable. (Bankr. W.D. Wis.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Taxes; Tax Period and Type.

ABI Membership is required to access the full summary of Acuna, In re--Acuna v. Ill. Dep't of Revenue Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on October 11, 2022 , LexisNexis #1222-081

Aikman v. IRS ( In re Aikman)

Ruling
Taxes and associated penalties were not dischargeable. (Bankr. W.D. Pa.)
Issue(s)
Was debtor entitled to the return of a tax refund retained by the IRS to pay taxes and penalties not paid in debtor’s bankruptcy?

ABI Membership is required to access the full summary of Aikman v. IRS ( In re Aikman) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on July 22, 2016 , LexisNexis #0816-074

Boykin v. Miss. Dept of Revenue (In re Boykin)

Ruling
State tax debt was nondischargeable to the extent the state department of revenue met its burden of proof.
Issue(s)
Was state tax debt for years 2007 through 2012 nondischargeable?

ABI Membership is required to access the full summary of Boykin v. Miss. Dept of Revenue (In re Boykin) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on May 06, 2016 , LexisNexis #0616-008

Nachimson, In re

Ruling
Debtor's 2015 and 2016 tax liabilities were excepted from debtor's discharge as they fell withinthe three-year look-back period. (Bankr. W.D. Okla.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Taxes; Tax Period and Type.

ABI Membership is required to access the full summary of Nachimson, In re Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on September 19, 2014 , LexisNexis #1019-058

Briggs v. United States (In re Briggs)

Ruling
Taxes due within three years of petition date were nondischargeable but taxes for earlier year in which debtor made good faith, but late attempt to file were dischargeable.
Issue(s)
Whether a tax return filed after the IRS has assessed the debt for the year in question qualifies as a "return?"

ABI Membership is required to access the full summary of Briggs v. United States (In re Briggs) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on June 09, 2014 , LexisNexis #0714-082

Winters v. Shulman (In re Winters)

Ruling
Nondischargeability of tax debt depended on amount of underreported income.
Issue(s)
Whether the bankruptcy court erred in finding that the Internal Revenue Service's claim of $226,142.85 for tax year 2004 was entitled to priority status in accordance with 11 U.S.C.S. § 507(a)(8) and, as such, was nondischargeable under 11 U.S.C.S. § 523(a)(1)(A).

ABI Membership is required to access the full summary of Winters v. Shulman (In re Winters) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on December 12, 2013 , LexisNexis #0114-012

Rizzo v. Michigan Dept of Treasury (In re Rizzo)

Ruling
Debtor's personal liability on state business tax debt was nondischargeable.
Procedural posture

Chapter 7 debtor, brought an adversary complaint against state taxing authority, seeking a determination that his personal liability for a tax debt under Michigan's Single Business Tax (SBT) that his business failed to pay was discharged because it was not a tax of the kind specified in 11 U.S.C.S. § 507(a)(8)(E) as being nondischargeable. The state moved to dismiss the complaint under Fed. R. Civ. P. 12(b)(6).

ABI Membership is required to access the full summary of Rizzo v. Michigan Dept of Treasury (In re Rizzo) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on August 01, 2012 , LexisNexis #0912-046

In re Lopez

Ruling
Debt for state sales tax not paid by debtor's business was nondischargeable.
Procedural posture

Chapter 7 debtor filed an adversary proceeding against defendant, the State of California State Board of Equalization ("SBE"), seeking a determination that a tax liability the SBE assessed under Cal. Rev. & Tax. Code § 6829 was dischargeable under 11 U.S.C.S. § 523(a)(1)(A). The case was tried to the court.

ABI Membership is required to access the full summary of In re Lopez Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on July 27, 2012 , LexisNexis #0912-047

State Empl. Dev. Dept v. Hansen (In re Hansen)

Ruling
State unemployment insurance tax was not a "tax required to be collected" and was dischargeable.
Procedural posture

Appellant, California Employment Development Department, challenged the U.S. Bankruptcy Court for the Eastern District of California's judgment that certain unpaid unemployment insurance taxes were not the kind of taxes specified in 11 U.S.C.S. § 507(a)(8)(C). It thus held that the unpaid unemployment insurance taxes in this case did not give rise to a nondischargeable debt within the meaning of 11 U.S.C.S. § 523(a)(1)(A). Appellees were debtors.

ABI Membership is required to access the full summary of State Empl. Dev. Dept v. Hansen (In re Hansen) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 18, 2012 , LexisNexis #0612-116

Ilko v. California State Bd. Of Equalization (In re Ilko)

Ruling
Bankruptcy appellate panel properly determined that state tax debt was nondischargeable.
Procedural posture

Chapter 7 debtor filed an adversary complaint against appellee, the California State Board of Equalization, seeking a determination that his liability under Cal. Rev. & Tax. Code § 6829(a) for a corporation's sales tax debt had been discharged. The bankruptcy court granted summary judgment in favor of the debtor. The United States Bankruptcy Appellate Panel (BAP) for the Ninth Circuit reversed. The debtor appealed.

ABI Membership is required to access the full summary of Ilko v. California State Bd. Of Equalization (In re Ilko) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on June 27, 2011 , LexisNexis #0711-088