Hands up everyone who has encountered a claim that a debt is non-dischargeable by reason of § 523(a)(14). That’s what I thought: nada, or next thing to it.
Despite watching for it, I hadn’t seen one ‘til this year when AmEx filed an adversary in a case in which I was peripherally involved. My copy of Collier’s code doesn’t comment on any (a)(14) cases.
To review, the Bankruptcy Reform Act of 1994 added §523(a)(14) making debt incurred to pay federal taxes that would be non-dischargeable . . .
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