Another circuit holds that tax debt on a late-filed tax return is rarely dischargeable in bankruptcy

The U.S. Court of Appeals for the Third Circuit has ruled that, except with respect to returns prepared with the assistance of the IRS, debts for unpaid taxes from late-filed tax returns aren’t dischargeable in bankruptcy. In so doing, it affirmed U.S. District Court and bankruptcy court decisions and also came to the same conclusion as the U.S. Appeals Courts in eight other circuits.