A common question that my clients ask is “will bankruptcy get rid of tax debt?” Like most legal issues, the answer is “it depends.” The good news is that as long as you meet the rules, taxes are dischargeable in bankruptcy.
Here’s the quick and dirty 5 part rule - Discharging Taxes in Bankruptcy:
- The Three Year Rule - the date for filing the return is more than three years old. So, for tax year 2010, you’d have to wait until 3 years from April 15th of 2011 (or October 15, 2011 if you filed an extension).
- The Two Year Rule - you must have actually filed your return more than two years ago.
- The 240 day Rule - any tax claim must have been assessed at least 240 days before filing.
- Non-Fraudulent Return - the tax return was non-fraudulent.
- No Willful Tax Evasion - you didn’t engage in activities deemed a “willful attempt to defeat or evade the tax.”
Combining tax law and bankruptcy law makes for a very complicated area. There are volumes of very lengthy books on this subject.
The important thing to remember is that taxes may be dischargeable in bankruptcy. Frequently, I meet with clients and even other professionals, including lawyers who believe that tax debts are never dischargeable in bankruptcy. This simply isn’t true!
Another common question I get is the difference between an offer in compromise and bankruptcy. In bankruptcy, as long as all the rules are met, the taxes are discharged in bankruptcy. In offer in compromise, the IRS has discretion to accept your offer or not.
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