Tax Debt is Dischargeable in Bankruptcy - The SFR | Blog

The statement is still correct, as long as you filed timely per the Tax Court Martin Decision SFR

Substitute For Return (SFR)

Under the right circumstances you might never have to pay taxes (the key statement is at 1:19). The rest of us have to pay taxes, and as part of the process we have to file tax returns. If you are required to file a return and dont do so, eventually the IRS will file a return on your behalf using the data it has on your income for the given tax year. Such a return is called a substitute for return (SFR). Once the SFR is complete, the IRS will enter the unpaid tax liability into its system. That process is called assessment. Unless you willing participate in the preparation of the SFR, the SFR is not a tax return for tax dischargeability.

See: The Ninth Circuits Martin DecisionSouthern California Bankruptcy Law Blog

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