Consumer Bankruptcy Journal Winter 2016 | Page 42

TOLLING EVENTS IN TAX DISCHARGE appears on the taxpayer’s IRS “Account Transcript” as either code “150,” “290,” or “300.” 5 This section starts out addressing an issue totally unrelated to tolling; Congress just closed its eyes and threw the tolling language in, and it stuck in subparagraph “G.” 6 What, exactly, constitutes “pending” is sometimes obscure? King, ¶ 2.9(d)(1)(iii). 7 See the “hanging” paragraph inserted into the code as part of the 2005 Bankruptcy Abuse Prevention and Consumer Protection Act, to wit, 11 U.S.C. § 507(a)(8)(G), referencing § 507(a)(8)(i) and (ii). 8 U.S. v. Dental Care Assoc (E.D.Wash 2016) 9 In re Tubman 364 B.R. 574 (Bankr.Md. 2007), In re Burnette, (Bankr. E.D.N.C. 2009); 10 CDP appeal may also be requested in the case of a notice of lien; 26 USC § 6320. 11 26 U.S.C. § 6330(a) and (b). Lastra v. United States, (Bankr.N.M. 2012). 1