By Morgan King, The Morgan King Company (Dublin, CA)

HELD: A taxpayer's returns filed long after the taxes were assessed did not satisfy the "honest and reasonable effort to satisfy the tax laws" under the Beard test.

Bell v. United States (In re Bell), 565 B.R. 702 (Bankr.M.D . . .

It looks like you are not signed in or registered! This content is only available to members.

Or Sign In Below:

No Author Biography has been linked to this Article.

Related Articles

BuzzyStubbs
September 29, 2024
It is with great sadness that we report the passing of Trawick "Buzzy" Hamilton Stubbs Jr. on September 25th.
October 20, 2019
By The Honorable William Houston Brown (Retired) Claim allowed after reopening of no-asset case. The Chapter 7 case filed as no-asset was reopened after discovery of assets for distribution, and debtors objected to a claim on basis of statute of limitations. Affirming, the Bankruptcy Appellate Panel held that the time to commence action on the claim had been tolled under...
Members
August 11, 2019
Summertime activities often affect the tax returns people file the following year. Here are some things taxpayers do during the summer along with tips they should consider now: Getting married. Newlyweds should report any name change to the Social Security Administration. They should also report an address change to the United States Postal Service, their employers, and the IRS. This...
Consumer Bankruptcy Education
May 11, 2025
On May 9th, the 2nd Circuit issued an opinion in Soussis v. Macco joining other Circuits holding that the Bankruptcy Code does not permit a Chapter 13 Trustee to retain the percentage fees collected on payments that a chapter 13 debtor made pre-confirmation in accordance with 26 U.S.C. §586 but, upon dismissal prior to confirmation of the plan, is obligated to return the fee to the debtor, as required by § 1326.
April 18, 2021
By Lawrence R. Ahern, III, Brown & Ahern (Nashville, TN) Introduction Analyzing the new "COVID-19 discharge" provision added to Chapter 131 by Congress on December 27 as part of the coronavirus emergency response legislation, the Bankruptcy Court for the Central District of California decided in In re Ritter2 that, in order to receive such a discharge, debtors must still comply...
Members
August 18, 2019
Taxpayers with expiring individual taxpayer identification numbers should renew their number ASAP. There are nearly 2 million ITINs set to expire at the end of 2019. Taxpayers with an expiring number should renew before the end of this year. This will help avoid unnecessary delays related to their tax refunds next year. ITINs are used by taxpayers required to file...
November 3, 2019
By Cathy Moran, Esq. (Redwood City, CA) After bankruptcy, credit scores go steadily up, says a 17 year study released by the Consumer Financial Protection Bureau. Got that? Go UP. Every year. Importantly, credit scores start improving the same year that the bankruptcy is filed. Think on that for a moment. How collectors stoke fears about bankruptcy Creditors and their...
February 3, 2019
By Edward C. Boltz, The Law Offices of John T. Orcutt (Durham, NC) (Originally published in pertinent part at ncbarblog.com, December 19, 2018) With the publication of Evicted: Poverty and Profit in the American City, author Matthew Desmond has brought increasing attention both nationwide and in North Carolina to the growing eviction crisis. With . . . It looks like...
Members
February 10, 2019
In June of 2017 Michele T. Hatcher was appointed Chapter 13 Standing Trustee for the Northern District of Alabama, Northern Division. Ms. Hatcher replaces retiring Trustee Michael Ford. She maintains her office in the quaint Southern town of Decatur which is nicknamed “The River City” because it is on the banks of Wheeler Lake, along the Tennessee River. Prior to...
Members
September 20, 2020
By The Honorable William Houston Brown (Retired) Three-month delay in completing bare-bones petition. When the Chapter 13 debtor filed a skeletal petition, her motion for more time to complete schedules, statement and plan was denied, with no cause found for extending time after three-month delay, and show cause hearing was set to determine if case should be dismissed with 180-day...
Members

Looking to Become a Member?

ConsiderChapter13.org offers a forum to advance continuing education of consumer bankruptcy via access to insightful articles, informative webinars, and the latest industry news. Join now to benefit from expert resources and stay informed.

Webinars

These informative sessions are led by industry experts and cover a range of consumer bankruptcy topics.

Member Articles

Written by industry experts, these articles provide in-depth analysis and practical guidance on consumer bankruptcy topics.

Industry News

The Academy is the go-to source for the latest news and analysis in the Chapter 13 bankruptcy industry.

To get started, please let us know which of these best fits your current position: