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HALL v. U.S.

No. 10-875.

132 S.Ct. 1882 (2012)

182 L.Ed.2d 840

Lynwood D. HALL, et ux., Petitioners v. UNITED STATES.

Supreme Court of United States.

Decided May 14, 2012.

Attorney(s) appearing for the Case

Susan M. Freeman , Phoenix, AZ, for Petitioners.

Pratik A. Shah , for Respondent.

Susan M. Freeman , Counsel of Record, Lawrence A. Kasten , Justin J. Henderson , Lewis and Roca LLP, Phoenix, AZ, Clifford B. Altfeld , Altfeld & Battaile P.C., Tucson, AZ, for Petitioners.

Donald B. Verrilli, Jr. , Solicitor General, Counsel of Record, John A. DiCicco , Principal Deputy Assistant, Attorney General, Malcolm L. Stewart , Deputy Solicitor General, Pratik A. Shah , Assistant to the Solicitor General, Bruce R. Ellisen , Patrick J. Urda , Attorneys, Department of Justice, Washington, DC, for the United States.

Justice SOTOMAYOR delivered the opinion of the Court.

Under Chapter 12 of the Bankruptcy Code, farmer debtors may treat certain claims owed to a governmental unit resulting from the disposition of farm assets as dischargeable, unsecured liabilities. 11 U.S.C. § 1222(a)(2)(A). One such claim is for "any tax ... incurred by the estate." § 503(b)(B)(i). The question presented is whether a federal income tax liability resulting from individual debtors' sale...

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