Central District Consumer Bankruptcy Attorney's Association

1. I found the remainder of the site and a link: http://www.irs.gov/pub/foia/ig/sbse/sbs ... 11-078.pdf
2. and for the other memo: http://www.irs.gov/pub/irs-ccdm/cc_2010_016.pdf
3. I read Henne (http://morganking.com/CASE%20OPINIONS8:09/Henne.pdf) as having failed the 3rd test of Beard and failed it badly. The Taxpayer was so evasive and engaged in such game playing that there was no way that the court was about to reward the bad behaviour.
4. Henne, if he had been planning to discharge anyway, could have submitted a return which had no deductions and which showed a higher tax than the SFR. Risky perhaps, but there would have been no audit-style challenge. He may have also listed a lot more detail and have avoided the "its the same as the SFR" problem as a further way to avoid failing prong 3 of the Beard test.
5. Henne also missed his opportunity to catch-up his returns immediately upon receiving the SFR and waay before the SFR-based assessment occurred, but he did not.
6. In any other regular case, other actions (short of placement immediately in condition for discharge) can be taken:
(a) apply to the IRS under 6404 to have the amount of tax abated as excessive given a legitimate, well-supported return.
(b) ask the bankruptcy court to adjudicate his tax liability (section 505) and as an ancillary matter whether the returns posted 2+ years ago met the standards of Beard. (BK Judge then has two bites at the tax apple as (1) did Taxpayer owe it, and (2) if he owed it does he meet Beard and can it be discharged).
7. Based upon the Lever facts, I would HOPE that the 2008 returns were very complete and very exacting supported, and well done. I know that people who are forgetful enough not to file are also likely to toss their records (and this is what I believe to be the source of the "your late return is no good" cases, and maybe given this approach they might not be as scary.)
8. Given the relationship with IRS insolvency unit, I'd get a stip in writing or press the items in #6 above as a max test on whether IRS insolvency might actually oppose. Maybe the position in both of the IRS pronouncements
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Dear John,
I found your comment quite compelling. And given the paucity - indeed, absence - of post-BAPCPA case law on the question, the substitute for return filing probably kills almost all possibility of a bankruptcy based tax discharge.
However, my curiosity is piqued, so I ask you the following because I know that you used to work for the IRS: How frequently are returns filed under 26 U.S.C. 6020(a)? My sense, based on an admittedly small sample size, is that almost all substitutes for return are 26 U.S.C. 6020(b) returns - meaning that the debtors are out of luck.
Thanks for your response.
Nick
Nicholas Gebelt, Ph.D., J.D.
Certified Bankruptcy Specialist
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charset="ISO-8859-1"
With all due respect to Morgan King, I'm a bit suspicious of this analysis.
BAPCPA amended the code at 11 usc 523 to read the following:
For purposes of this subsection, the term return means a return that
satisfies the requirements of applicable nonbankruptcy law (including
applicable filing requirements). Such term includes a return prepared
pursuant to section 6020(a) of the Internal Revenue Code of 1986, or similar
State or local law, or a written stipulation to a judgment or a final order
entered by a nonbankruptcy tribunal, but does not include a return made
pursuant to section 6020(b) of the Internal Revenue Code of 1986, or a
similar State or local law.
Several post-BAPCPA cases state as dicta that the amendment means that no
one can ever discharge a tax where the IRS filed an SFR and then assessed.
I don't quite agree with that reading, but I have not found a post-BAPCPA
case that holds that a post-SFR return triggers a dischargeable tax. Given
the amendment, I'm not sure that Nunez and other pre-2005 cases are still
good law, and I don't see a discussion of this point in the excerpt below.
John D. Faucher
Hurlbett & Faucher, LLP
5743 Corsa Ave., Suite 208
Westlake Village, CA 91362
(818) 889-8080
Fax: (805) 367-4154
http://www.hurlbettfaucher.com/
3324 State Street, Suite O
Santa Barbara, CA 93105
(805) 963-9111
This electronic mail message and any attached files are confidential,
contain information intended for the exclusive use of the individual or
entity to whom it is addressed, and may be legally privileged. If you are
not the intended recipient, please immediately reply to John Faucher (at
818/889-8080 or john@hf-bklaw.com )
indicating that you received this message and then delete the message
without delay. Thank you for your cooperation.
Disclosure Under U.S. IRS Circular 230: The recipient may not use any tax
advice contained in this communication, including any attachments, for the
purpose of avoiding federal tax related penalties or promoting, marketing or
recommending to another party any particular transaction or matter.
On 12/5/11 7:03 PM, "Steven B. Lever" wrote:
>
>
>
>
>
> Mark;
>
> Thank you very much. Ill be studying your response for some time to come.
> It is very complex. At first read it seems pretty equivocal as to how the
> IRS will look at this with a lack of controlling authority. However, it is
> clear that my client could not have waited longer to file and have a different
> result, so his legal position is pretty much in stone on this issue as to the
> facts, although not the law.
>
> Steve
>
>
Mark
> J. Markus
> Sent: Monday, December 05, 2011 6:22 PM
> To: cdcbaa@yahoogroups.com
> Subject: Re: [cdcbaa] Substitute for Return
>
>
>
> Steve,
>
> The following is excerpted from Morgan King's recent Bankruptcy Academy
> newsletter.
>
> Specifically, in a case where the IRS filed a substitutefor-
> return ("SFR" - sometimes called a service-filed
> return), and then has proceeded to assess the tax,
> and only then has the taxpayer filed his/her 1040
> return, is that return a valid return for purposes of the
> 6-Story Newsletter Template + Images 12/5/11 5:57 PM
> http://app.topica.com/campaigns/preview ... 5&typehtml Page 8 of
> 12
> 2-year rule?
> HELD VALID RETURNS
> The jurisdictions are not in agreement on this issue.
> While several courts have held that such a return is
> not a valid return, including the 4th and 6th circuits,
> others have rejected a per se rule that a post-SFR
> post-assessment return is never a valid return.
> Instead, those opinions are characterized by the rule
> that the question should be decided on a case-bycase
> basis. Those opinions cite the Beard case and
> hold that the key question is whether the return
> indicates an honest attempt to comply with the tax
> regulations. In In re Nunez (link to full opinion below)
> the court said:
> " . . . the preparation of substitute returns and
> assessment by the IRS does not act as a complete
> bar to efforts by the Debtor to file a return. That is, the
> Debtor can still take actions which will satisfy Section
> 523(a)(1)(B).
> "We also agree with the reasoning of the bankruptcy
> court, and the other courts that have so held, that
> Congress could have conditioned discharge of tax
> debt on whether a return was filed prior to an
> assessment. As correctly noted by the court,
> Congress used assessment as a trigger for other time
> periods in the Code, for example, the priority
> qualifications found in Section 507(a)(8)(A)(ii).
> "When Congress includes particular language in one
> section of the Code, but omits it in another, it is
> presumed to have acted intentionally and purposely.
> [cite] We will not read into Section 523(a)(1)(B) the
> requirement that a debtor must have filed a return
> prior to an assessment by the IRS."
> In re Nunez, 232 B.R. 778 (B.A.P. 9th Cir., 1999)
> The most recent case holding a post-SFR postassessment
> return to be a valid return appears to be
> the 8th Circuit ruling in In re Colsen. Here the court
> observed:
> "The government's essential position is that because
> Mr. Colsen's 1040 forms were filed after the IRS's
> assessment, they do not evince an honest, genuine
> attempt to satisfy the law and thus he has not satisfied
> the requirement that returns be filed in order for tax
> liabilities to be dischargeable. But we have no
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> http://app.topica.com/campaigns/preview ... 5&typehtml Page 9 of
> 12
> evidence to suggest that the forms appeared
> obviously inaccurate or fabricated; indeed, Mr.
> Colsen's 1040 forms contained data that allowed the
> IRS to calculate his tax obligation more accurately:
> The information contained in the forms was honest
> and genuine enough to result in thousands of dollars
> of abatements of tax and interest.
> "This contrasts, incidentally, with the situation in
> Hindenlang, 164 F.3d at 1031, where the taxpayer's
> forms contained essentially the same information as
> the substitute forms that the IRS prepared and the
> calculation of tax did not change substantially.
> "The IRS apparently has found post-assessment
> returns useful, as it has required taxpayers to file them
> before the agency would consider proposed offers to
> compromise tax liabilities. See Payne, 431 F.3d at
> 1060. Filing the forms served an important purpose
> under the tax laws for Mr. Colsen. That the IRS did
> not also collect more tax as a result of Mr. Colsen's
> filings does not undermine their role in determining
> Mr. Colsen's ultimate liabilities.
> "The theory of the case that the government espouses
> holds only if we consider the accurate calculation of a
> taxpayer's obligations not to be a valid purpose that
> satisfies the tax laws, which we decline to do."
> In Re: Gary Wayne Colsen, 446 F.3d 836 (8th Cir.
> 2006)
> Cases holding returns were valid:
> In re Payne, 331 B.R. 358 (Bankr. N.D. Ill., 2005)
> In Re: Gary Wayne Colsen, 446 F.3d 836 (8th Cir.
> 2006)
> In re Nunez, 232 B.R. 778 (B.A.P. 9th Cir., 1999)
> In re Crawley), 244 B.R. 121, 127-28
> (Bankr.N.D.Ill.2000)
> In re Woods, 285 B.R. 284 (Bankr. S.D. Ind., 2002)
> NOT VALID RETURNS
> The contrary has been held in a number of cases. In
> In re Henne the court observed:
> "In this case, the post-assessment Forms 1040 were
> treated as a request for reconsideration and, had the
> Debtor responded to IRS's request for verification of
> items reported on his belated Forms 1040, the
> submissions may have affected his tax liability.
> 6-Story Newsletter Template + Images 12/5/11 5:57 PM
> http://app.topica.com/campaigns/preview ... 5&typehtml Page 10 of
> 12
> "However, the Debtor did not follow up with the IRS
> after filing his submissions in 1998, and he failed to
> respond to the IRS's requests for supporting
> documentation. The Debtor testified that the IRS
> examiner was "very helpful" when he met with her in
> 1997, but he made no effort to contact her or anyone
> at IRS concerning his post-assessment submissions.
> "His lack of action supports the finding that he did not
> expect his post-assessment forms to affect his tax
> liability i.e., "to satisfy the requirements of the tax
> law." And, in fact, the late submissions had no tax
> consequences."
> In re Henne, 359 B.R. 776 (Bankr.Ariz., 2007)
> But note that the Henne ruling does not actually
> contradict the rulings in the above cases, which
> basically rejected a per se rule and held that each
> case should be looked at on a case-by-case basis. In
> looking at the facts in Henne the court merely found
> that the debtor's conduct as a whole evidenced a lack
> of a good-faith effort to comply with the tax laws.
> Cases holding returns were invalid:
> U.S. v. Klein, 312 B.R. 443 (S.D. Fla., 2004)
> In re Henne, 359 B.R. 776 (Bankr.Ariz., 2007)
> In re Hindenlang, 164 F.3d 1029, 1033 (6th Cir.)
> United States v. Ralph, 266 B.R. 217, 219
> (M.D.Fla.2001)
> In re Ehrig, 308 B.R. 542 (Bankr. N.D.Okla., 2004)
> In re Moroney, 352 F.3d 902 (4th Cir., 2003)
> In re Miniuk, 297 B.R. 532 (Bankr. N.D. Ill., 2003)
> SUMMARY OF THEORIES
> Looking at the cases, the theories appear to boil down
> to the following:
> 1. Serve no valid purpose. Where the return merely
> mimics the assessment, the return serves no valid
> purpose. However, some cases hold that such returns
> are nevertheless valid if they appear valid on their
> face and satisfy the 4-prong test of the Beard case.
> 2. The return corrects an erroneous IRS
> assessment: it serves a purpose and is more likely to
> be deemed a valid return. However, some cases hold
> that even those returns are invalid.
> 3. The 4-part Beard test. Almost all of the cases
> apply the 4-parts of a valid return as prescribed by the
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> http://app.topica.com/campaigns/preview ... 5&typehtml Page 11 of
> 12
> Beard case. These are: 1) Purports to be a return, 2)
> Contains the math necessary to do an assessment, 3)
> is signed under penalty of perjury, 4) represents a
> good-faith effort to comply with the filing requirements.
> There is little official discussion of the Beard test in
> publicly available IRS literature. One memo contains
> the following:
> "In general, a document filed with the Service is
> treated as a return if the document: (1) contains
> sufficient data to calculate the tax liability; (2) purports
> to be a return; (3) represents an honest and
> reasonable attempt to satisfy the requirements of the
> tax law; and (4) is executed under penalties of perjury.
> Beard v. Commissioner, 82 T.C. 766, 777 (1984),
> affd, 793 F.2d 139 (6th Cir. 1986) (citing Badaracco v.
> Commissioner, 464 U.S. 386 (1984); Zellerbach Paper
> Co. v. Helvering, 293 U.S. 172 (1934); and Florsheim
> Bros. Drygoods Co. v. United States, 280 U.S. 453
> (1930))." Internal Revenue Bulletin: 2005-37
> PARTIALLY VALID RETURN?
> An interesting twist to this issue that does not appear
> to be addressed in any published opinion, is whether a
> post-SFR post-assessment 1040 could be partially
> valid, and partially invalid.
> In an internal memorandum dated Sept. 28 2011 the
> IRS provided guidance in cases of post-SFR, postassessed
> 1040s, and stated the IRS position that a
> tax already assessed could not be the basis for a valid
> return subsequently filed, but also made this
> interesting observation:
> "When the debtor submits a Form 1040 after the
> assessment under IRC 6020(b), only the portion of
> the tax that was not previously assessed would be
> subject to discharge."
> In other words, if the taxpayer's 1040 shows more tax
> owed than was assessed, the additional tax would be
> deemed assessed because of that 1040, thus
> rendering that portion of the return a valid return for
> purposes of the 2-year rule.
> While this scenario may be rare, it is worth including
> on a checklist somewhere.
> IRS Memorandum SBSE-05-0911
>
>
> *************************
> Mark J. Markus
> Law Office of Mark J. Markus
> 11684 Ventura Blvd. PMB #403
> Studio City, CA 91604-2652
> (818)509-1173 (818)509-1460 (fax)
> web: http://www.bklaw.com/
> This Firm is a Qualified Federal Debt Relief Agency (see what this means at
> http://bklaw.com/bankruptcy-blog/2008/0 ... efinition/)
> ________________________________________________
> NOTICE: This Electronic Message contains information from the law office of
> Mark J. Markus that may be privileged. The information is intended for the use
> of the addressee only. If you are not the addressee, note that any disclosure,
> copy, distribution or use of the contents of this message is prohibited.
> IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by the
> IRS, we inform you that any U.S. tax advice contained in this communication
> (or in any attachment) is not intended or written to be used, and cannot be
> used, for the purpose of (i) avoiding penalties under the Internal Revenue
> Code or (ii) promoting, marketing or recommending to another party any
> transaction or matter addressed in this communication.
>
> On 12/5/2011 1:21 PM, Steven B. Lever wrote:
>
> I have a question about tax dischargeability after a substitution for return.
>
> I researched my question in the forums website and found an exchange between
> Jeff Smith, Peter Lively, John Faucher and Dennis McGoldrick from December
> 2010 that is reproduced below, and is chronologically read from the bottom up.
>
> However, I remain confused.
>
> I recently filed an emergency for a client who has a large judgment
> enforcement but also has a significant tax debt from 2004/2005. Both years
> have substitute returns. He finally filed his actual return in 2008.
>
> He also established an installment agreement in 2008, so hes been paying for
> more than 2 years, although it may have gone to other years than just
> 2004/2005 and theres no way of tracing it.
>
> So QUESTION: Are 2004/2005 dischargeable (1) in full, or (2) only for the
> portion that was assessed after the filing of the actual returns, or (3)
> nothing is dischargeable.
>
>
>
>
>
> Law Offices of Steven B. Lever
>> >
>> > Steven B. Lever
>> > ******************************************************
> Re: [cdcbaa] Tax Discharge Substitute For Return
>
> Dennis.
>
>
>
> See Morgan King article in Sept. issue of Norton's Bankruptcy Law Advisor,
> entitled "What is a Tax Return?"
>
>
>
> This strategy appears to only help discharge the subsequent assessment not the
> original debt assessed in SFR.
>
>
>
> Peter M. Lively, JD/MBA
> Law Office of Peter M. Lively * Personal Financial Law Center I
> 11268 Washington Blvd, Suite 203, Culver City, CA 90230-4647
> Telephone: (310)391-2400 * (800)307-3328 * Fax: (310)391-2462
> A-Bankruptcy-Attorney.com
> Personal Financial Law Center II - Costa Mesa, CA
>
> THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH
> IT IS ADDRESSED, AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL
> AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE
> IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR
> DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT
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> IMMEDIATELY BY E-MAIL OR BY TELEPHONE. THANK YOU.
>
>
>
>
> To: "cdcbaa@yahoogroups.com"
>
> Sent: Sun, December 12, 2010 8:54:32 PM
> Subject: Re: [cdcbaa] Tax Discharge Substitute For Return
>
>
> There is a solution. File a return and ask for an audit reconsideration. If
> IRS adjusts the amount due as a result of the filing, tax becomes
> dischargeable. Have to get a two year installment agreement, to pass the two
> year test. I do them.
>
> D
>
> Sent from my iPhone
>
> On Dec 9, 2010, at 11:34 AM, "John D. Faucher" d5wObgkf0XAZFR7L_qmwUHuvIv6ft4Cy0qf8zp8z3cVhpWC0vARUX8Vyl8c2YhEX> > wrote:
>
> I just researched it yesterday, and it still seems to be the rule.
>
> John D. Faucher
> Hurlbett & Faucher
> 5743 Corsa Ave., Suite 208
> Westlake Village, CA 91362
> (818) 889-8080
> Fax: (805) 367-4154
> http://www.hurlbettfaucher.com/
>
> 3324 State Street, Suite O
> Santa Barbara, CA 93105
> (805) 963-9111
>
> This electronic mail message and any attached files are confidential, contain
> information intended for the exclusive use of the individual or entity to whom
> it is addressed, and may be legally privileged. If you are not the intended
> recipient, please immediately reply to John Faucher (at 805/963-9111 x103 or
> john@...
> 5M71n_Sea248xtwdgtNshjlrakv8gULGSrMQDELmTU6ZjnC4HR_l1c8> ) indicating that you
> received this message and then delete the message without delay. Thank you
> for your cooperation.
>
> Disclosure Under U.S. IRS Circular 230: The recipient may not use any tax
> advice contained in this communication, including any attachments, for the
> purpose of avoiding federal tax related penalties or promoting, marketing or
> recommending to another party any particular transaction or matter.
>
> EzuHb_ySJRSyLR7ILumURzJ148qmg-elImBrBo-TOdMQvEcQCouOQ_Qznms> >
> Reply-To: zFIpNBSclXTQ8taljnB0xzhoeTDRkBJDhG3tE3vuSd0daJUhXfZhikj7s9npy_ab7w> >
> Date: Thu, 09 Dec 2010 02:03:37 -0000
> To: 5vwH6xp-CsUVzj6UtCsd6c9RaONeXS-i8xsueE4BwmnfgWqdnmWAPAn-6D_LulEEJQ> >
> Subject: [cdcbaa] Tax Discharge Substitute For Return
>
>
> Is the rule still that there is no hope for the debtor who had a substitute
> for return filed by the agency. That's always been my understanding. Seems
> Draconian to me so I have always assumed someone would challenge that sooner
> or later. I looked and found no new law, but wanted to mine the collective
> consiousness.
>
> -Jeffrey B. Smith**
> CURD, GALINDO & SMITH, L.L.P.
> 301 East Ocean Blvd. #1700
> Long Beach, CA 90802
> (562) 624-1177
> (562) 624-1178 fax
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>
> **Certified By The State Bar
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> In Bankruptcy Law
>
>
>
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With all due respect to Morgan King, I'm a bit suspicious of this analysis. BAPCPA amended the code at 11 usc 523 to read the following: For purposes of this subsection, the t
The post was migrated from Yahoo.

Mark;
Thank you very much. I'll be studying your response for some time to come. It is very complex. At first read it seems pretty equivocal as to how the IRS will look at this with a lack of controlling authority. However, it is clear that my client could not have waited longer to file and have a different result, so his legal position is pretty much in stone on this issue as to the facts, although not the law.
Steve

The post was migrated from Yahoo.

Steve,
The following is excerpted from Morgan King's recent Bankruptcy
Academy newsletter.
Specifically, in a case where the IRS filed a substitutefor-
return ("SFR" - sometimes called a service-filed
return), and then has proceeded to assess the tax,
and only then has the taxpayer filed his/her 1040
return, is that return a valid return for purposes of the
6-Story Newsletter Template + Images 12/5/11 5:57 PM

The post was migrated from Yahoo.

I have a question about tax dischargeability after a substitution for
return.
I researched my question in the forum's website and found an exchange
between Jeff Smith, Peter Lively, John Faucher and Dennis McGoldrick
from December 2010 that is reproduced below, and is chronologically read
from the bottom up.
However, I remain confused.
I recently filed an emergency for a client who has a large judgment
enforcement but also has a significant tax debt from 2004/2005. Both
years have substitute returns. He finally filed his actual return in
2008.
He also established an installment agreement in 2008, so he's been
paying for more than 2 years, although it may have gone to other years
than just 2004/2005 and there's no way of tracing it.
So QUESTION: Are 2004/2005 dischargeable (1) in full, or (2) only for
the portion that was assessed after the filing of the actual returns, or
(3) nothing is dischargeable.
Law Offices of Steven B. Lever
>
> Steven B. Lever
> ******************************************************
Re: [cdcbaa] Tax Discharge Substitute For Return
Dennis.
See Morgan King article in Sept. issue of Norton's Bankruptcy Law
Advisor, entitled "What is a Tax Return?"
This strategy appears to only help discharge the subsequent assessment
not the original debt assessed in SFR.
Peter M. Lively, JD/MBA
Law Office of Peter M. Lively * Personal Financial Law Center I
11268 Washington Blvd, Suite 203, Culver City, CA 90230-4647
Telephone: (310)391-2400 * (800)307-3328 * Fax: (310)391-2462
A-Bankruptcy-Attorney.com
Personal Financial Law Center II - Costa Mesa, CA
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO
WHICH IT IS ADDRESSED, AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED,
CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE
READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR
AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT,
YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING
OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY E-MAIL OR BY
TELEPHONE. THANK YOU.
________________________________

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