By The Honorable William Houston Brown (Retired)
Plan did not clearly provide for discharge of unpaid tax debt. Discussing the typical plan that would not pay postpetition interest on unsecured claims, the Bankruptcy Appellate Panel distinguished § 507(a)(8)(C) priority “trust fund” tax claims, which are excepted from discharge under § 1328(a)(2). The debtor remains liable after discharge for any unpaid portion of those tax claims, including accrued postpetition interest. The plan did not provide for discharge of the § 507)(a)(8)(C) tax claim, although it provided for payment of the claim in . . .
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