TAX REMEDIES – The King Law Reporter December 2017 # 1
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The King Law Reporter December 2017 # 1
Hosted by Fastcase.com & The Morgan King Company
Providing prompt notice of new cases, emerging issues, and other timely and important information for professionals who deal with delinquent taxes.
TWO CENTS WORTH
We continue to get calls from taxpayers complaining that their bankruptcy lawyer promised back taxes would be discharged in bankruptcy, but after final discharge they discover that the IRS does not agree.
When we look into the matter, we sometimes find that the lawyer did not bother to get the debtor’s Account Transcripts, which, if carefully examined, often show one or more events that may render the delinquent taxes nondischargeable.
We suggest that lawyers presented with delinquent tax cases either refer them out to more expert professionals to handle, or at least to study the transcripts, or, learn how to translate IRS Account Transcripts.
Sometimes the task of obtaining and interpreting documents from state taxing entities is confusing, because some states do not always use the vocabulary employed by the IRS, or the Bankruptcy Code, or use it in different ways. For example, if you ask a state tax officer when were the assessments?, you may find that he or she has no clue, because they don’t use the word “assess.” Hence, it is difficult to analyze some state tax liabilities for dischargeability.
Recently a fair number television commercials have appeared by entities purporting to be tax relief experts. Some of them use fear to attract taxpayers’ attention, like “The IRS is coming down hard on taxpayers who owe taxes.” They word it to suggest that this is something recent, or new, as though the IRS had just begun an aggressive, new campaign to collect back taxes. These claims are a bit disingenuous.
Historically, the IRS has been more aggressive in the past. These days, due to cutbacks in hiring, IRS people tend to be overworked, such that there less aggressive hassling taxpayer’s.
In fact, the number of offers accepted by the IRS has risen substantially in recent years. Here are recent remarks by TaxDebtHelp.com:
“The IRS recently released their annual offer in compromise (OIC) data for 2016. Although the acceptance rate fell in fiscal year 2014 and 2015, it reached a new all-time high in 2016 with an acceptance rate of 42.86%. That is almost 1% more than the previous all-time high reached in fiscal year 2013.”
“Some of the commercials allude to the “Fresh Start Initiative” (FSI) as though it was an exciting recent development. But the Fresh Start Initiative was adopted in 2011 – almost 7 years ago. Again, talking about the FSI as a newly announced opportunity is a bit disingenuous.”
Some remedies not explored properly
There is too much hype over new tax relief remedies, but what alarms us more is that most of the entities on television are not attorneys, and hence do not know how to identify when a tax liability can be discharged in bankruptcy. Instead of steering the taxpayer into a quick, easy bankruptcy, they charge a substantial fee to do an offer-in-compromise, which may, or may not, be accepted by the IRS.
Bankruptcy has several benefits not available in the typical OIC.
For example, an OIC may take the IRS a year or more to decide whether or not to accept it; in contrast, the typical chapter 7 is over and done with in 90 days.
Another big difference, whether or not to accept, or reject, an OIC, is up to the IRS. In contrast, the IRS has no say about whether a tax is, or is not, dischargeable. This lifts a lot of stress off the taxpayer.
And, the amount of paperwork that the taxpayer and his/her tax representative must prepare is far more voluminous, and time-absorbing, than the paperwork in the typical bankruptcy case.
IRS tax collectors abusing taxpayers
A recent report from the U.S. Treasury Department, release on September 28, 2017 revealed that there were a number of cases of IRS tax collectors abusing taxpayers. The report addressed complaints (IRS) administrative or civil actions resulting from violations of Fair Tax Collection Practices (FTCP).
The audit is included in IRS Fiscal Year 2017.
In addition to the Faiar Tax Collections Act, the report makes it plain that tax collectors are subject to the Fair Debt Collection Practices Act, and is included in the recently adopted Fair Tax Collection Practices Violations (Sept. 2016).
To ensure equitable treatment of debt collectors in the public and private sectors, the IRS Restructuring and Reform Act of 1998 requires the IRS to comply with certain provisions of the Fair Debt Collection Practices Act.
1. Requires the IRS to comply with certain provisions of the Fair Debt Collection Practices Act.
|2. Specifically, the IRS may not communicate with taxpayers in connection with the collection of any unpaid tax:|
In addition, the IRS may not harass, oppress, or abuse any person in connection with any tax collection activity or engage in any activity that would naturally lead to harassment, oppression, or abuse. Such conduct specifically includes, but is not limited to:
1. Use or threat of violence or harm.
2. Use of obscene or profane language.
3. Causing a telephone to ring continuously with harassing intent.
4. Placement of telephone calls without meaningful disclosure of the caller’s identity.
TIGTA identified four FTCP violations closed in Fiscal Year (FY) 2016 that resulted in administrative actions for IRS collection employees performing collection activities.
Two revenue officers contacted taxpayers directly without the required consent of the taxpayers’ power of attorney, one contact representative harassed or abused taxpayers, and one contact representative used obscene or profane language with taxpayers.
Administrative actions were taken by the IRS to address these violations: one revenue officer resigned in lieu of termination, one revenue officer received a 10 -day suspension, one contact representative received a 10-day suspension, and one contact representative was admonished. The disciplinary actions received by all four employees were consistent with the range of penalties set forth in the IRS Manager’s Guide to Penalty Determinations.
The report noted that Internal Revenue Code § 7433 provides that a taxpayer may bring a civil action for damages against the Federal Government if an officer or employee of the IRS recklessly or intentionally, or by reason of negligence, disregards any provision of the Internal Revenue Code or related regulation in connection with the collection of Federal tax. There were no civil actions resulting in monetary awards for damages to taxpayers because of an FTCP violation in FY 2016.
Reporter December 2017 # 1
CASE & COMMENT
Interest on IRS taxes not discharged
See King’s Discharging Taxes in Consumer Bankruptcy Cases, at ¶ 3.11(f)(4), ¶ 3.13.
The debtor filed a chapter 13 case with a plan that provided for full payment of unsecured priority trust-fund taxes. The principal of the liability was paid in full in the debtor’s chapter 13.
Following the final discharge, the IRS sent the debtor a notice of their intention to levy for the post-petition interest that had accrued, but not paid, in the Plan.
The court held that, unlike a secured claim, the plan could not provide for payment of postpetition interest on a non-dischargeable tax. The Bankruptcy Code § 1322(a)(10) provides that the plan may provide for payment of postpetition interest on unsecured nondischargeable taxes (e.g., trust-fund taxes) but only if the plan is a 100% plan.
“Section 502(b)(2), however, does not mean that interest ceases to accrue or that a debtor is exonerated therefrom. Rather, post-petition interest accrues outside the Chapter 13 plan and the debtor remains personally liable therefor post discharge.”
The Thaxton court appears to acknowledge that, in some cases, postpetition interest on nondischargeable taxes would be discharged, but only if the plan so provided, and the IRS had been given adequate notice of that plan provision. In this case, this did not happen:
“They made no mention of their intent to pay only the principal of the claim. They also did not tender a clear, open and explicit statement that interest accrued post-petition would be discharged.”
|“In the absence of language clearly providing for a discharge of the priority tax claim for so-called trust fund taxes, the debtor failed to give the IRS the clear, open, and unambiguous notice of any intent to discharge such claim which the decision in Espinosa and due process requires. In the absence of such notice… “|
See also, In re Hanna, 872 F.2d 829, 831 (8th Cir. 1989); Johnson v. Internal Revenue Serv. 146 F.3d 252, 260 (5th Cir. 1998). Our Court of Appeals is in accord. See In re Kielisch, 258 F.3d 315, 321-22 (4th Cir. 2001).
Ed. note This is an issue that has been addressed in King’s Discharging Taxes, and described as a “trap for the unwary.”
April 11 2017
Held, IRS position that debtor’s conduct in not paying taxes amounted to wilful tax evasion, is subject to a full evidentiary hearing, and hence IRS motion for summary judgment was denied.
The conduct component includes actions intended to avoid not only the assessment of taxes but also the collection thereof, examples of which may be “keeping a double set of books, making false entries or alterations, or false invoices or documents, destruction of books or records, concealment of assets or covering up sources of income, handling one’s affairs to avoid making the records usual in transactions of the kind, and any conduct, the likely effect of which would be to mislead or to conceal.”
The willfulness component is a quintessential question of fact to be determined from the totality of the record. By requiring proof that a debtor subjectively intended to evade or defeat a tax debt, § 523(a)(1)(C) preserves the discharge for debtors whose non-reporting or non-payment of taxes arises from inadvertence, mistake, or confusion; only debtors who engage in knowing and deliberate tax avoidance are denied discharge of their tax debts.
ed. note: the IRS Manual provides a checklist of fraud or evasion indicators at:
IRM § 18.104.22.168 (11-05-2014)
- Misrepresentation of material facts
- False or altered documents
- Evasion (i.e., diversion or omission)
- The courts focus on key badges of fraud in determining whether there was an “intent to evade” tax. A determination of fraud is based on the taxpayer’s entire course of conduct, with each badge of fraud given the weight appropriate to a particular case.
- An evaluation of fraud is based on the weight of the evidence rather than the quantity of the factors.
Some of the common “first indicators (or badges) of fraud” include:
Per IRS Manual:
- Fictitious or improper deductions (e.g., overstatement of deductions, personal items deducted as business expenses)
- Accounting irregularities (e.g., two sets of books, false entries on documents)
- Obstructive actions of the taxpayer (e.g., false statements, destruction of records, transfer of assets, failure to cooperate with the examiner, concealment of assets)
- A consistent pattern over several years of underreporting taxable income
- Implausible or inconsistent explanations of behavior
- Engaging in illegal activities (e.g., drug dealing), or attempting to conceal illegal activities
- Inadequate records
- Dealing in cash
- Failure to file returns, and
- Education and experience
This topic is addressed in King’s Discharging Taxes at ¶ 2.4(h).
Held, returns filed within 3 years of the due date are excepted from discharge.
Forrester v. Internal Revenue Serv. (In re Forrester) (Bankr.S.D.Ala., 2017)
This topic is addressed in King’s Discharging Taxes at ¶ 2.4(e)
Reporter December 2017 # 1
From, King’s Discharging Taxes in Consumer Bankruptcy Cases, available at The Morgan King Company.
¶ 5.16 ADMINISTRATIVE REMEDIES
See also ¶ 5.5(e)(6), ¶ 5.9(h) ¶ 5.10, ¶ 5.11(b)(3)(g)
a. In general
Internal Revenue Code § 7430 permits taxpayers to obtain damages, administrative and litigation fees, and costs under certain limited circumstances. Congress enacted § 7430 “to deter abusive actions or overreaching by the [IRS] and to enable taxpayers to vindicate their rights regardless of their economic circumstances.” Section 7430 constitutes a waiver of sovereign immunity, and must be strictly construed. Code § 7433(b) provides for damages and litigation costs (e.g., attorneys’ fees) but only if administrative remedies have been exhausted per § 7433(d)(1) and 7433(e), and Treasury regulations § 301.7430(-1) and § 301.7433-2(d).
CAVEAT: Litigation seeking a declaration of discharge of IRS taxes does not require prior exhaustion of administrative remedies, but the weight of authority is that seeking damages or attorney’s fees and costs does.
In those cases, and in those jurisdictions which interpret 26 U.S.C. § 7430 and § 7433 to require exhaustion of administrative remedies before commencing an action in bankruptcy court for violation of the automatic stay or the discharge, the question is, what exactly are the administrative remedies to which the debtor must comply?
In order to be entitled to claim litigation costs (attorney’s fees and costs), the claimant must satisfy three elements (§ 7430):
1. Exhaustion of administrative remedies § 7430(b)(1), § 7433(d)
The terms attorney’s fees, prevailing party and reasonable litigation costs and unjustified position are defined at § 7430(c).
b. Period to apply for administrative costs
26 U.S.C. § 7430(b)(4) provides that a request for administrative costs must be made within 90 days of the final decision of the IRS in connection with an administrative determination.
c. Violation of automatic stay
Litigation costs may be awarded where the debtor prevails in an action (motion or adversary proceeding) for damages for violation of the automatic stay under 11 U.S.C. § 362(k).
See ¶ 5.16(g)(2)
d.Violation of discharge
Section 26 U.S.C. §§ 7430 and 7433, providing the exclusive remedy for violation the discharge under § 524, requires a petition in the bankruptcy court.
e.Declaratory decree of discharge
The debtor may file an adversary action to determine the dischargeability of any debt, at any time. Bankruptcy Rule 4007; Rule 7001(6). Since all of the Tax Code and Code of Federal Regulations provisions addressing the requirement for exhausting administrative remedies refer only to actions seeking damages, an action merely seeking to determine the dischargeability of the taxes does not appear to require prior exhaustion of administrative remedies.
A complaint seeking declaratory judgment of discharge, as well as damages for violation of section 524, was not defective for failure to exhaust administrative remedies, but the debtor would have to establish that administrative remedies had been exhausted in order to seek damages
f.Procedure for administrative remedies
See also ¶ 5.16(f)(3)
Two administrative procedures are described in the tax code and treasury regulations.
(1) Administrative Appeal. – Treasury regulation – 26 CFR § 301.7430-1 is entitled “Exhaustion of administrative remedies.” This section requires, as a prerequisite to an award for costs of litigation in Tax Court, that the taxpayer first pursue whatever administrative appeal procedures are available, specifically, that the taxpayer ” … participates … in an Appeals office conference, or has filed a request for an Appeals conference, and filed a written protest if required.” This subject is beyond the matter addressed in this book and will be not elaborated on here.
(2) Demand letter. 26 U.S.C. § 7433 provides that a prerequisite to any action seeking damages in federal district court, or bankruptcy court for violation of either 11 U.S.C. § 362 or § 524 (§ 7433(e)(1)) must exhaust administrative remedies.
The Treasury regulations explain the requirements:
(e) Actions involving willful violations of the automatic stay under section 362 or the discharge provisions under section 524 of the Bankruptcy Code-
(1) Section 7433 claims. A party has not exhausted administrative remedies within the Internal Revenue Service with respect to asserted violations of the automatic stay under section 362 of the Bankruptcy Code or the discharge provisions under section 524 of the Bankruptcy Code unless it files an administrative claim for damages or for relief from a violation of section 362 or 524 of the Bankruptcy Code with the Chief, Local Insolvency Unit, for the judicial district in which the bankruptcy petition that is the basis for the asserted automatic stay or discharge violation was filed pursuant to §301.7433-2(e) and satisfies the other conditions set forth in §301.7433-2(d) prior to filing a petition under section 7433.
(2) Section 362(h) claims. A party has not exhausted administrative remedies within the Internal Revenue Service with respect to asserted violations of the automatic stay under section 362 of the Bankruptcy Code unless it files an administrative claim for relief from a violation of section 362 of the Bankruptcy Code with the Chief, Local Insolvency Unit, for the judicial district in which the bankruptcy petition that is the basis for the asserted automatic stay violation was filed pursuant to §301.7433-2(e) and satisfies the other conditions set forth in §301.7433-2(d) prior to filing a petition under section 362(h) of the Bankruptcy Code.
2. Exhaustion of administrative remedies required
a. Administrative remedies are required
26 CFR § 301.7430-1(e) provides that actions involving willful violation of § 362 or 524 under 26 U.S.C. § 7433 require exhaustion of administrative remedies:
“A party has not exhausted administrative remedies within the Internal Revenue Service with respect to violations of the automatic stay under section 362 of the Bankruptcy Code or the discharge provisions under section 524 of the Bankruptcy Code unless it files an administrative claim for damages or for relief … with the Chief, Local Insolvency Unit, for the judicial district in which the bankruptcy petition … was filed … and satisfies the other conditions set forth in § 301.7433-2(d) prior to filing the petition under section 7433.”
The court in In re Consol Health Services explored the requirement to exhaust admin. remedies for violation of the automatic stay.
In that case the IRS contacted the debtor seeking to recover a penalty in violation of the stay. The trustee gave the IRS written notice of the stay and the effect of the stay on tax collection. The trustee explained that they should back off from sending him notice of intent to levy for the time being.
Notwithstanding this notice, the IRS followed up with a notice of intent to levy to the debtor. Over a period of two years the trustee repeatedly warned the IRS to stop, and the IRS ignored the warnings.
The trustee filed a motion for sanctions for violation of the stay. The opinion recites the key events:
“The IRS still maintained, however, that this court has no jurisdiction even to hear this matter, because a party seeking to recover a civil penalty against the IRS must first exhaust certain administrative remedies required by 26 U.S.C. § 7433 and 26 C.F.R. § 301.7433-2(e).
In response, the trustee argued that § 7433(e), if applicable, can be read to provide an exclusive remedy in the bankruptcy courts that is essentially exempt from the administrative process requirement; and, further, that if § 7433(e) does include an exhaustion of administrative remedies requirement, his efforts to resolve the repeated stay violations constitute substantial compliance with that requirement.”
The court held that the trustee must first exhaust administrative remedies:
“in context of IRS violations of discharge injunction, that taxpayer must comply with “jurisdictional” exhaustion of remedies requirement in § 7433 prior to petitioning bankruptcy court); [cites] … debtors were required to exhaust administrative remedies before proceeding with motion for contempt in context of IRS’s violation of discharge injunction); [cite] … taxpayers seeking damages pursuant to 26 U.S.C. Section 7433 . . . are required to exhaust their administrative remedies available within the IRS” “
The IRS generally argues that, pursuant to IRC § 7430(b)(1) and 7433, where the adversary proceeding includes a prayer for payment of administrative costs and litigation costs, the taxpayer/debtor must comply with the requirement to first exhaust administrative remedies. And, again, to seek any kind of damages for violation of the discharge the plaintiff must exhaust administrative remedies.
The weight of authority is that, pursuant to 26 U.S.C. § 7433, § 7433(d)(1), and CFR § 301.7433-1, before commencing an action in bankruptcy court seeking sanctions (damages) against the IRS for violation of either § 362 or § 524, the debtor must first “exhaust administrative remedies.”
The court in Pointer observed that the weight of authority is that the debtor must exhaust administrative remedies before seeking sanctions or damages in bankruptcy court.
 In re Klauer, 362 B.R. 31, 34 (Bankr.M.D.Fla. 2006) (citing Weiss v. Commissioner of Internal Revenue, 88 T.C. 1036, 1041, 1987 WL 49313 (1987); citing H.R.Rep. No. 97-404, 97th Cong., 1st Sess., at 11 (1981)).
 Klauer, at 34.
 In re Matthews 184 B.R. 594, 601 (S.D.Ala. 1995).
 26 C.F.R. § 301.7433-2 Civil cause of action for violation of section 362 or 524 of the Bankruptcy Code; (a)(2).
 Kight v. IRS 108 A.F.T.R. 2d 2011-7061 (Sept. 20 2011); 460 B.R. 555 (Bankr.M.D.Fla., 2011)
 In re Dorminy, 301 B.R. 599 (Bankr.M.D.Fla. 2003) (the IRS motion for summary judgment as to the prayer seeking a declaration of discharge was based, not on failure to exhaust remedies, but rather whether or not a prior stipulation entered in Tax Court rendered the issue res judicata; the court held that it did not).
 The term “administrative proceeding” means any procedure or other action before the Internal Revenue Service.” 26 U.S.C. § 7430(c)(5).
 26 CFR § 301.7430-1(d)
 In re Consol. Health Servs., Inc. (Bankr. E.D.N.C., 2013)
 Consol Health, at 2.
 Control Health, at 5.
 Aaron, supra.; In re Klauer 362 B.R. 31, 34 (Bankr.M.D.Fla. 2006); In re Swensen, 438 B.R. 195, 198 (Bankr.N.D.Iowa 2010); In re Cooper, __ B.R. __ (Bankr.M.D.N.C. 2011) (violation of automatic stay under 11 U.S.C. § 362); In re Jha, 108 A.F.T.R.2d 2011, 461 B.R. 611 (Bankr. N.D. Cal., 2011).
 Pointer v. United States (In re Pointer), 510 B.R. 433 (Bankr.M.D.Ga., 2014); Moreno v. United States (In re Moreno) (Bankr. E.D. Cal., 2015); In re Graycarr, Inc., 330 B.R. 741, 747 (Bankr. W.D. Ark., 2005).
Fastcase Expands into Original Works by Launching Full Court Press, a New Print and Digital Imprint.
Fastcase Introduces the First Journal of New Publication Portfolio with RAIL: The Journal of Robotics, Artificial Intelligence & Law
Washington, DC (November 2, 2017) – Today Fastcase announced the November launch of its inaugural publication, RAIL: The Journal of Robotics, Artificial Intelligence & Law, continuing its quest to add unique, must-have content for its subscribers and provide leading legal analysis with contributions from firm partners across the country.
The publication of RAIL is the first title from the new Fastcase imprint, Full Court Press, the new publishing arm of Fastcase. RAIL is a multimedia offering, available in print, as an eBook, in audio, and exclusively within the Fastcase legal research application.
Fastcase co-founders Ed Walters and Phil Rosenthal continue to challenge the status quo in the legal publishing industry. Since founding Fastcase in 1999, they have consistently pursued the mission to democratize the law, making it more accessible to more people. In bringing Steve Errick to the team as Chief Operating Officer earlier this year, Fastcase began pursuing additional opportunities to build out original authored works.
“When Ed and Phil asked me to come to Fastcase to build out their content portfolio, I asked if they were ready to serve their authors and customers with an ‘all-in’ commitment to publishing content in customer-friendly media formats,” said Errick. “RAIL brings together a fantastic board and contributors, covering an emerging field closely associated with Fastcase and a commitment to distributing content in every suitable media to the delight of our authors and author partners.”
“Full Court Press is like Netflix for legal publishing,” said Walters. “Together with our partners in bar associations and law firms, we’ve built a very powerful platform, running more than 4 million searches per month, and we’re improving it by adding our own original series through Full Court Press. RAIL is our first of many offerings, including legal treatises, deskbooks, forms, checklists, and workflow tools. We’re just getting started.”
“Steve is a publishing pro, bringing in top talent to drive the program and showing our team the value of developing author relationships that will add to the long-term success of Full Court Press in creating leading authored analysis. As other publishers retreat from books we’re uniquely positioned to start a print plus imprint that incorporates our expertise in technology and online publishing whether to help support and drive the book programs of our state bar partners, or in launching our own imprint,” noted Fastcase President Phil Rosenthal.
The 2018 roadmap for Full Court Press includes co-developing digests, journals, books, and blogs with an array of partners, including state and specialty bar associations, leading law schools and law firms, and franchise authors who have a long history of working with Errick, and who embrace Fastcase as a steward of their works.
The inaugural publication, RAIL, includes contributions from industry-leading experts:
Morgan Morrissette Wright
Steven A. Meyerowitz
President, Meyerowitz Communications Inc.
Victoria Prussen Spears
Senior Vice President, Meyerowitz Communications Inc.
TopForm was one of the pioneering expert systems for law. Now that TopForm is a Fastcase company, we’re applying the same passion for great software that revolutionized the legal research field, and bringing it to one of the most revered expert systems for bankruptcy filings.
That’s why Lawyerist said, “Fastcase Plans to Make Kick-Ass Bankruptcy Software a Reality.” The move from CD-ROM to downloadable software was the first step, and the move to TopForm Web is the next phase of bankruptcy filing software. Now you can file anywhere, any time, and on any device!
IN OTHER NEWS
Resident warns against scam calls
– Alana Chargualaf | The Guam Daily Post
– Nov 21, 2017
Around 3 a.m. recently, Moore-Linn answered her phone and heard what must have been a prerecorded message.
After saying “Hello,” she immediately heard a voice say, “If you do not pay what you owe, a lawsuit will be filed against you.” The voice then recited a phone number to call. Moore-Linn knew that she and her husband pay taxes to the government of Guam, not the IRS, so she didn’t fall for it.
The IRS stated on its website irs.gov that many taxpayers have encountered individuals impersonating IRS officials – in person, over the telephone and via email.
IRS sends mail
To avoid getting scammed, the IRS reminds taxpayers the it initiates most contacts through regular mail delivered by the U.S. Postal Service.
RESEARCH & RESOURCES
LAWYERS IN THE NEWS
RACHEL FOLEY JOINS NACBA BOARD OF DIRECTORS
In addition to her training through the UAW, Rachel’s background as a Risk Manager for Clarkson Regional Health Center and 20 years’ experience in the emergency room as a Registered Respiratory Therapist, makes her uniquely qualified to argue a variety of cases.
Rachel has been recognized for her constant commitment to the representation of debtors. Rachel is the inaugural winner of the K. Colleen Nunnelly Award by the National Association of Consumer Bankruptcy Attorneys and recognized by her peers as being the Best of the Kansas City Bar in the area of bankruptcy. These recognitions are in addition to being named to the Pro Bono Wall of Fame by the Missouri Bar Association.
Abusive Debt Collection
IRS Collection Due Process
Consumer Chapter 11
Discharging Student Loans
Fundamentals of Bankruptcy Law & Practice
The Means Test
Avoiding & Stripping Liens
Fees & Ethics
3-Vol. Tax Practice Library
12-Book Bankruptcy Library
12-CD Bankruptcy Library
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