Thomas E. Raleigh, Chapter 7 Trustee for the Estate of William J. Stoecker, v. Illinois Department of Revenue (530 U.S. 15)
U.S. Supreme Court · decided May 30, 2000 · Supreme Court Database (Spaeth)
- Citation
- 530 U.S. 15 · 120 S. Ct. 1951
- Decided
- May 30, 2000
- Term
- October Term 1999
- Vote
- 9–0
- Majority author
- Justice Souter
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice Souter delivered the opinion of the Court. The question raised here is who bears the burden of proof on a tax claim in bankruptcy court when the substantive law creating the tax obligation puts the burden on the taxpayer (in this ease, the trustee in bankruptcy). We hold that bankruptcy does not alter the burden imposed by the substantive law. I The issue of state tax liability in question had its genesis in the purchase of an airplane by Chandler Enterprises, Inc., a now-defunct Illinois company. William J. Stoeeker, for whom petitioner Raleigh is the trustee in bankruptcy, was president of Chandler in 1988, when Chandler entered into a lease-purchase agreement for the plane, moved it to Illinois, and ultimately took title under the agreement. See In re Stoecker, 179 F. 3d 546, 548 (CA7 1999). According to respondent State Department of Revenue, the transaction was subject to the Illinois use tax, a sales-tax substitute imposed on Illinois residents such as Chandler who buy out of State. If the seller does not remit the tax, the buyer must, and, when buying a plane, must file a return and pay the tax within 30 days after the aircraft enters the State. Ill. Comp. Stat., ch. 35, §105/10 (1999). Chandler failed to do this. When the State discovers a failure to file and pay taxes, its Department of Revenue (the respondent here) determines the amount of tax due and issues…
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