Tax Penalties


The treatment of unsecured tax penalties in bankruptcy is related to the dischargeability of the tax to which they are related. Generally:

Chapter 7

• Penalties associated with priority (nondischargeable) taxes are not dischargeable;
• Penalties related to dischargeable taxes are dischargeable, too.
• Penalties associated with taxes arising more than three years before the bankruptcy are dischargeable, even if the tax to which it is linked isn't dischargeable.

Chapter 13

• All unsecured penalties are dischargeable. Penalties can be paid at the same rate as non tax claims, usually a fraction on the dollar.
• No new penalties accrue on pre-petition taxes during the Chapter 13 payment plan.
If a tax lien attaches to actual equity in assets, the penalties are secured as well as the tax, even if they would be dischargeable if not secured.

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