Third Circuit Weighs in on Dischargeability of Late Filed Tax Debts

In a recent decision, the Third Circuit Court of Appeals determined whether Internal Revenue Service Forms 1040, filed after the IRS has made an assessment of the taxpayer’s liability, constitute “returns” for purposes of determining the dischargeability in bankruptcy of tax debts under 11 U.S.C. § 523(a)(1)(B).  In plain language, the question before the Court […]

Supreme Court Issues Long Awaited Jevic Ruling, Ending Structured Dismissals in Bankruptcy

As a general proposition, Chapter 11 bankruptcy proceedings can conclude in one of three ways:  (1) confirmation of a plan of reorganization (or liquidation); (2) conversion to Chapter 7; or (3) dismissal.  Ideally, a plan is confirmed in which creditors receive payment as required under the distribution scheme embodied in the Bankruptcy Code. Plans can provide […]

No Retreat, Baby, When You Surrender

Under Section 521 of the Bankruptcy code, an individual debtor is obligated to choose how to treat the collateral of a secured creditor. Under the Code, the choices are: reaffirm the debt, redeem the collateral, surrender it, or claim the property as exempt. The debtor must file a Statement of Intention which explicitly lists the […]

Bankruptcy Court Approves Client’s Reorganization

On January 11, 2017, the United Stated Bankruptcy Court for the Eastern District of Pennsylvania entered an order confirming the Chapter 11 Plan of Reorganization of the Firm’s client, ColdEdge Technologies, Inc., after a lengthy bankruptcy proceeding.   ColdEdge was formed in 2008 and provides cryogenic equipment for use in the research laboratory setting. Shortly […]

Supreme Court: Fraud Means Fraud

People engaged in schemes falling within the historical purview of “actual fraud” will no longer find refuge in the bankruptcy courts.