By Cathy Moran, Esq., (Redwood City, CA)
Eighteen years elapsed between the close of the 2003 tax year and the Tax Court’s 2021 decision Barnes v. Comm'r, T.C. Memo. 2021-49 (U.S.T.C. May 4, 2021) regarding the debtors’ 2003 tax liability.
While the most recent decision in the debtors’ battle with the IRS challenged the discretion of a tax officer in rejecting debtors’ settlement offer after completion of debtors’ Chapter 11, the case is instructive to Chapter 13 lawyers for two points: