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“Straddling the Line”: Delaware Bankruptcy Court Rules That Not All Tax Liabilities Incurred During a Debtor’s Petition Year are Eligible for Administrative Expense Priority

In re Affirmative Insurance Holdings, Inc., Case No. 15-12136 (CSS), 2019 WL 5173773 (Bankr. D. Del. Oct. 15, 2019).

In this Opinion, Chief Judge Sontchi ruled that tax liabilities incurred by a corporation during a year that “straddles” the petition date should be bifurcated, such that tax liabilities stemming from post-petition events are afforded administrative expense priority, whereas tax liabilities stemming from pre-petition events are afforded general unsecured status.  In so doing, his Honor departed from the previous practice of affording administrative expense priority to tax liabilities incurred by a corporate debtor during the year of its petition date in their entirety.

The debtors in this case (the “Debtors”) were engaged in the business of providing non-standard personal automobile insurance to individual consumers in targeted geographic markets.   In October of 2015, the Debtors filed for chapter 11 relief in the Delaware Bankruptcy Court.  Thereafter, the Debtors’ cases converted to chapter 7 proceedings.  Post-conversion, the Internal Revenue Service (the “IRS”) filed an administrative expense claim for income taxes for the 2015 tax year, which it later amended (the “IRS Claim”).  In so doing, the IRS asserted that all corporate taxes (inclusive of interest and penalties) incurred by the Debtors during the 2015 calendar year were entitled to administrative expense priority.  The Chapter 7 Trustee objected to the IRS claim, on the basis that all material taxable events giving rise to the applicable taxes occurred pre-petition.

In order to resolve the dispute, the Delaware Bankruptcy Court made a two-part inquiry: (i) whether the IRS Claim was a priority claim under section 507(a)(8) of the Bankruptcy Code; and if not, (ii) whether the IRS Claim was an administrative expense claim.  The Court quickly dispensed with the first prong of its analysis, finding that section 507(a)(8) is inapplicable to taxable years that straddle the petition date, and as such moved to the second portion of its inquiry.

Prior to the implementation of BAPCPA the Third Circuit held that “straddle tax years” must be bifurcated into (at the time) priority and unsecured claims.  Chief Judge Sontchi opined that, although BAPCPA had the substantial impact of creating a priority claim for tax years that ended on or before the petition date, in no way would the Bankruptcy Court’s refusal to afford administrative expense priority to tax costs stemming from pre-petition events create an ambiguity regarding Congress’ intention in BAPCPA relating to priority claims for tax years ending on or before a debtor’s petition date.

Importantly, the Court was faced with determining the priority of the IRS Claim, not the amount.  As such, Chief Judge Sontchi found that there was nothing in either bankruptcy or tax law that prevented the Court from allowing disparate treatment of different portions of claims.  Indeed, Chief Judge Sontchi opined that although the amount or liability may be decided at the conclusion of the applicable tax year, the administrative priority of such liability must turn on whether the estate incurred the claim post-petition.  As such, the Bankruptcy Court bifurcated the IRS Claim, holding that the Debtors’ tax liabilities stemming from post-petition events were afforded administrative expense priority, whereas the Debtors’ tax liabilities stemming from pre-petition events were afforded general unsecured status.

Takeaway: Trustees should be mindful of taxing agencies seeking administrative expense priority for tax liabilities incurred during the entire year in which a debtor filed for bankruptcy.  Only tax liabilities stemming from events actually occurring after a debtor’s petition date are eligible for such priority.

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