Michigan Dep’t of Treasury v. Hight (In re Hight), 670 F.3d 699, 705 (6th Cir. 2012) (Martin, Gibbons, Steeh)

Straddling tax claim for 2008 state income taxes was prepetition claim in 2009 case, entitled to priority by § 507(a)(8)(A)(i) and (iii) and § 502(i); debtor can file protective proof of claim on behalf of state under § 501(c). “The district court correctly interpreted the Bankruptcy Code in finding that § 1305 does not exclusively govern the filing of postpetition claims and that Hight was permitted to file a protective claim under § 501(c) because §§ 502(i) and 507(a)(8) establish that she could treat a postpetition claim for a tax debt arising from the immediately preceding tax year as if it were a prepetition claim.”

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