Hall v. United States

Docket No.	Op. Below	Argument	Opinion	Vote	Author	Term
10-875	9th Cir.	Nov 29, 2011 Tr.Aud.	May 14, 2012	5-4	Sotomayor	OT 2011

Holding: The federal income tax liability resulting from petitioners’ post-petition farm sale is not “incurred by the estate” under Section 503(b) of the Bankruptcy Code and thus is neither collectible nor dischargeable in the Chapter 12 plan.

Plain English Summary: At issue was whether farmers who sell their farm while in bankruptcy have to pay capital gains tax to the IRS. The farmers argued that they could sell the farm and give the proceeds to their other creditors. However, the Court agreed with the IRS that the IRS must be paid before the other creditors.

Judgment: Affirmed, 5-4, in an opinion by Justice Sotomayor on May 14, 2012. Justice Breyer filed a dissenting opinion in which Justices Kennedy, Ginsburg and Kagan joined.

SCOTUSblog Coverage

Opinion analysis: When worlds collide, the IRS wins and bankrupts shudder (Ronald Mann)
Argument recap: Justices balance tax and bankruptcy policy (Ronald Mann)
Argument preview: Justices balance tax and bankruptcy policy (Ronald Mann)

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The Supreme Court released additional orders from the January 11 conference on Monday; the justices called for the views of the U.S. solicitor general in CSX Transportation Inc. v. Alabama Department of Revenue, Alabama Department of Revenue v. CSX Transportation Inc. and Toshiba Corp. v. Automotive Industries Pension Trust Fund.
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Cases argued	43
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Hall v. United States

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Briefs and Documents

Certiorari-stage documents

Featured Posts

Challengers urge justices to dismiss census case after district court ruling – Amy Howe

Reargument analysis: Justices seek a “middle position” in takings litigation case – Miriam Seifter

Argument analysis: Justices have strong views about removal of class actions – Ronald Mann

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