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the bankruptcy court, because the debts were nondischargeable
under 11 U.S.C. sec. 523(a)(1)(B) and (C)).
Petitioner also fails to appreciate the effect of lien under
SEC. 6321. LIEN FOR TAXES.-- which provides:
If any person liable to pay any tax neglects or
refuses to pay the same after demand, the amount
(including any interest, additional amount, addition to
tax, or assessable penalty, together with any costs
that may accrue in addition thereto) shall be a lien in
favor of the United States upon all property and rights
to property, whether real or personal, belonging to
such person.
The lien arises at assessment and continues until the liability
is satisfied or becomes unenforceable because of lapse of time.
Section 6322.
IV. Dischargeability Under Section 523(a)(1)(B) of the
Bankruptcy Code.
A Chapter 7 debtor generally is discharged from all debts
that arose before the filing of the bankruptcy petition under 11
U.S.C. sec. 727(b). Certain debts, however, are excepted from
discharge under 11 U.S.C. sec. 523. 11 U.S.C. section
523(a)(1)(B)(i) excepts a tax debt from discharge in bankruptcy
if a debtor was required to file a tax return with respect to
such tax but failed to file one. A purpose of the return
requirement in section 523(a)(1)(B) is to “prevent a debtor who
has ignored the filing requirements from escaping liability for
unpaid taxes through the debtor’s own misconduct.” Swanson v.
Commissioner, 121 T.C. at 122 (citing In re Hindenlang, 164 F.3d
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