tax

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Seventh Circuit Holds Illinois Tax Purchaser Entitled to 18% Interest Rate in Chapter 13

Divided Court Holds Tax Purchaser Has a “Tax Claim” Under § 511(a); Judge Hamilton Warns Decision Gives Private Investor a Windfall and Makes Chapter 13 Relief More Difficult

In In re Romero, No. 25-2021 (7th Cir. July 16, 2026), the Seventh Circuit affirmed a bankruptcy court ruling that an Illinois tax purchaser holds a “tax claim” under 11 U.S.C. § 511(a) and is entitled to an 18% annual interest rate when its claim is paid through a Chapter 13 plan.

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Second Circuit Holds Debtor Lacked Standing to Seek Preemptive Determination of Tax Dischargeability

Court Rules Bankruptcy Court Should Have Deferred to IRS’s Later-Filed—but First Jurisdictionally Proper—District Court Action

In In re Goebel, No. 25-103 (2d Cir. July 28, 2026), the Second Circuit held that a Chapter 7 debtor lacked Article III standing to obtain a determination of the dischargeability of federal income-tax debts where, at the time she filed her adversary complaint, the IRS had not taken any concrete action indicating that it intended to assert that the debts were nondischargeable.

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