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U.S. v. VERDUNN

No. 95-2614.

89 F.3d 799 (1996)

UNITED STATES of America, Plaintiff-Appellant, v. Thomas B. VERDUNN, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

July 31, 1996.

Attorney(s) appearing for the Case

Gary R. Allen, U.S. Tax Division, Dept. of Justice, Edward T. Perelmuter, Gary D. Gray, Washington, DC, for appellants.

B. Gray Gibbs, Gibbs & Runyan, P.A., St. Petersburg, FL, for appellee.

Before KRAVITCH and CARNES, Circuit Judges, and HILL, Senior Circuit Judge.

HILL, Senior Circuit Judge:

In this case we decide whether a debtor's federal income tax liabilities and penalties, asserted by the Commissioner of the Internal Revenue Service (Commissioner) in a statutory notice of deficiency and the subject of dispute in a Tax Court petition filed by the debtor, are liquidated unsecured debts for Bankruptcy Code Chapter 13 eligibility purposes. The bankruptcy court concluded they were not. The district court affirmed. We disagree...

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