Cornelius P. Young, et Ux. v. United States (535 U.S. 43)
U.S. Supreme Court · decided March 4, 2002 · Supreme Court Database (Spaeth)
- Citation
- 535 U.S. 43 · 122 S. Ct. 1036
- Decided
- March 4, 2002
- Term
- October Term 2001
- Vote
- 9–0
- Majority author
- Justice Scalia
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Scalia delivered the opinion of the Court. A discharge under the Bankruptcy Code does not extinguish certain tax liabilities for which a return was due within three years before the filing of an individual debt- or’s petition. 11 U. S. C. §§ 523(a)(1)(A), 507(a)(8)(A)(i). We must decide whether this “three-year lookback period” is tolled during the pendency of a prior bankruptcy petition. I Petitioners Cornelius and Suzanne Young failed to include payment with their 1992 income tax return, due and filed on October 15, 1993 (petitioners had obtained an extension of the April 15 deadline). About $15,000 was owing. The Internal Revenue Service (IRS) assessed the tax liability on January 3, 1994, and petitioners made modest monthly payments ($40 to $300) from April 1994 until November 1995. On May 1,1996, they sought protection under Chapter 13 of the Bankruptcy Code in the United States Bankruptcy Court for the District of New Hampshire. The bulk of their tax liability (about $13,000, including accrued interest) remained due. Before a reorganization plan was confirmed, however, the Youngs moved on October 23, 1996, to dismiss their Chapter 13 petition, pursuant to 11 U. S. C. § 1307(b). On March 12, 1997, one day before the Bankruptcy Court dismissed their Chapter 13 petition, the Youngs filed a new petition, this time under Chapter 7. This was a “no asset” petition,…
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