Open Bankruptcy Project

The Return-Filing Rule — § 523(a)(1)(B)

The third dischargeability rule: the debtor must have actually filed a return (not just had the IRS prepare a substitute-for-return), and that return must have been filed more than 2 years before the bankruptcy filing.

The rule's two components

Under § 523(a)(1)(B), tax debt is non-dischargeable if:

  1. (B)(i) The return was not filed, OR
  2. (B)(ii) The return was filed less than 2 years before the bankruptcy filing

The "filed return" requirement

The return must be a return prepared and signed by the taxpayer. An IRS-prepared substitute for return (SFR) under § 6020(b) does NOT count for this purpose under most circuit-level interpretations. The taxpayer must have actually filed.

If the IRS assessed via SFR and the taxpayer never filed a return, the tax is non-dischargeable indefinitely (as long as the return remains unfiled).

Late returns and the One-Day-Rule problem

The most contentious issue: what if the taxpayer filed a late return after the IRS had already assessed via SFR?

Several circuit positions have emerged:

The split is real and unresolved at the Supreme Court level. Circuit-level law controls in any specific case.

The 2-year requirement

Even if the late filing qualifies as a "return," § 523(a)(1)(B)(ii) requires that the return have been filed more than 2 years before the bankruptcy. Filing a late return immediately before bankruptcy doesn't satisfy this.

Practical implications