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LETTER NO. 173

 

WHAT THEY SAY ABOUT THE FUNDAMENTALS COURSE

About King's 35-hour course, Fundamentals:

 

"Outstanding! Content - great! Visuals are outstanding! Test is good learning device for recall."
 

           - Carol Cross Stone Esq., Long View, TX

CASE HOTWIRE

HELD:  CHAPTER 13 PLAN REQUIRES A "DEFINITE" PERIOD OF TIME PURSUANT TO LOCAL RULES 

 

 In re Escarcega, 573 B.R. 219 (B.A.P. 9th Cir. 2017)   

 

"These cases, taken together, establish that Debtors' plans must specify a length and cannot contain provisions which essentially amount to plan modifications shortening that length without complying with the procedural requirements of § 1329 and without obtaining a court order."

 

HELD: CHAPTER 13 PLAN NEED NOT HAVE A "DEFINITE" PERIOD OF TIME 

  

In re Flinn (Bankr. Kan. 2020)   

 

"Nothing in the Code demands it be a whole number. One certainly couldn't logically argue that the words "a longer period" as found in § 1322(d) and § 1329(c) by themselves dictate that said period be a definite number of months or years. Rather, the period can be "longer" than three years but not more than five." 

WHAT THEY SAY ABOUT OUR BOOKS & PUBLICATIONS

 

BANKRUPTCY & TAX PUBLICATIONS

"It is no hyperbole to say that I am astonished at the detail in your materials and how intuitive they are.  It seems that I often pursue one line of research that peters out except when I use your stuff.  I mean it.  your bankruptcy and tax materials cover my practice perfectly."

 

- Bruce N. Crawford, Esq. MN Bar

 

"Buy Morgan King's book. It's worth so much more than the price. It will enlighten and is a great companion to the software and seminar. However, it's not for the faint of heart."

- Terry O'Neill, E.A. Round Hil, Va.

 

"Morgan, so many of us look up to you in our BK practices. You have really set a high bar for the rest of us! Thank you and congratulations on many fronts!"

- John Gist, Esq. California Bar, 2020

"There was the Fees & Ethics thumb drive. Thank you so much. I brought it in and started looking at it. Right off the bat, in the Preface it lists exactly what needs to be focused on. Great!"

- Madeline McIntosh, Esq. Texas Bar, 2020

 

"Thank you very much for sending that publication. It is an excellent set of materials ..."

- Wayne E. Johnson, Los Angeles, CA 1998 (appointed judge of the bankruptcy court, Central District, CA.  2011)

 

"I learned a lot and still rely on the Tax Discharge Book. That's invaluable."

- Edward Gonzales, Esq., Wa. D.C. 2012

"I have two books by Morgan King: Discharging Taxes in Consumer Bankruptcy Cases and IRS Offers in Compromise.

 

"As a 52-year practicing attorney, with 48 of those years in active bankruptcy practice, I think these books are the most practical and helpful law books I have ever used.  I consult often with both books in my daily practice and find the answer almost all the time.   

 

"Thank you, Morgan, for helping lawyers give their clients the best possible service."

 

- Marion E. Wynne Esq. Fairhope, AL 10/07/2019 

 

I enjoyed reading your book on taxes. I have many good contacts with Georgia Department of Revenue here. The revenue officers like to see my cases as I usually get my Chapter 13 tax lien stripping cases approved without a lot of hassle.

 

One of the regional officers dropped by my office a few years ago to introduce himself. He said he wanted to say hello since I was the only one down here in this corner that knew what they were doing. I thought you might get a little laugh out of that one.

 

Shelba Sellers, Esq.  07/13/19

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I have been using your practice guide with GREAT success.  Thank you.  I just ordered the forms CD.  But then got to wondering if I should buy the update/recent version to my practice guide??

 

My daughter just got licensed and I am insisting that she read the practice guide cover to cover.

- Timothy Trichler, Esq.

Cadillac, MI 2019

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It is so great to have such a "top" go-to person! I know so many people who are in need of your services.

- Client K. P.

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Morgan, I just want you to know that you are a hero to those of us in the trenches in bankruptcy work. Thanks for sharing your knowledge, analysis and experience!.

- Richard Pettys, Jr., J.D.

Woodstock, Georgia

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I'm a big fan of yours and have two of your books--a little outdated. You have done so much to educate the BK/Tax bar!

- Michael K. Mehr, Esq. Santa Cruz, CA Feb. 14 2018

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Morgan, Your work is GREAT!

- Richard I. Isacoff, J.D. , Western New England University School of Law (N.Y.)

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King Bankruptcy Books provides some of the most trusted and unique content in the consumer bankruptcy market.

- Phil Rosenthal, CEO, FastCase.

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Mr. King is the pre-eminent authority in the bankruptcy community ...

- Robert Sampson, Director of Customer Service, Pitbulltax

__________

 

When I'm reading King's book on discharging taxes I feel like the Burning Bush is speaking to me.

- Kelly Nebiolini, Esq. Oakdale, CA

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The book is wonderful! Great stuff ... perfect format! -

Roberto Rivera, paralegal, Cinneminson, NJ

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I have purchased other books from you - - - including Discharging Taxes and McGoldrick's Chapter 11 - - - These are my bible - - - both old and new testaments!" -

- Patrick Greenwell, Esq. Sonoma, CA

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I LOVE Mr. King's website and all of the books and seminars he offers.   We can't wait to order more.  You're in the monthly budget!

- Kathleen M. Roberts, Paralegal, Palm City, FLA

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Your publication is considered the most authoritative by people I know in the business.

- Ryan Davies, Esq. Lake Forest, CA

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The King expertise has saved many a bankruptcy attorney from going nuts. I handle only small business and tax cases have 25 plus years experience and the King guide is something I could not do without.

 

I would endorse Morgan's books anytime. Thank you for all the hard work in giving us something practical and well researched. When the law changed and you came out with the Reform Guide, I knew I had to have it. It helped me feel competent getting back to work.

- Marguerite Kirk , Esq. Fort Worth,TX Board Certified Business Bankruptcy American Board Bankruptcy Certification,

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I really appreciate the great information you provide for us bankruptcy attorneys. As a solo, I don't think I would make it without your resources. Thank you!

- Alexis Crow, Esq. Charlottesville, VA

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I need your highly recommended book sooner rather than later.

- Allan Pearlman, Esq. New York, N.Y.

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Thanks for doing what you do. There's a tremendous need for it. I know of several atty's in my area who don't know (enough) about tax discharge. More EA's who practice representation need this knowledge as well. Our clients aren't effectively served if we don't present all their options.

- Lisa Sexton, E.A., Carlsbad, N.M.

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Every serious bankruptcy practitioner should have this book!

 

- Ike Shulman, former President of the National Association of Consumer Bankruptcy Attorneys, San Jose, CA

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Any practitioner who does any degree of bankruptcy tax work or analysis would be crazy not to have this tax discharge treatise! I found it immensely practical, helpful, insightful, and comprehensive.

- Matthew Tozer, Esq.,Fullerton, CA

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I have been a panel trustee for over 15 years, and I routinely attend the Southeastern conference in Atlanta and the NABT conferences. I have found your book to be extremely helpful.  It is the best organized book of its type I have ever utilized. -

- Thomas H. Fluharty, Chapter 7 panel trustee, Clarksburg, WV

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Thank you for your response.  I, as all in this field, truly appreciate your comments as the recognized expert in this difficult area. -

- Gerald H. Davis, San Diego

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Mr. Morgan, the book was worth the wait!

- Kenneth Allen

__________

 

I have recently ordered some of your books, in particular, the one related to discharging taxes in bankruptcy.  I appreciate the invaluable information you have given other attorneys.  As a small ( 2 person office) it is very difficult to venture outside your comfort zone of area of practice.  The books and especially the listserve help me to do that.  I cannot thank you enough.

- Bob Ellis, Columbus Ohio

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As a bankruptcy practitioner for fourteen years I can say beyond question that every bankruptcy practitioner should purchase this book.

- Michael Mehr, Santa Cruz, CA

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One of the most helpful legal books I have ever read. It is concise, well organized, and full of practical information not available elsewhere. -

August Bullock, San Francisco, CA

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As a tax lawyer, tax professor and tax author, I think your treatise is the best in its field.

- Kneave Riggal, South Pasadena, CA

 

Get the book to me on Wednesday! Please don't fail me!

- Frantic lawyer, Los Angeles, CA

__________

 

The Franchise Tax Board's Insolvency Estate Unit will be using the book as a technical filed guide for the staff. We have recently placed an order for additional copies. -

 

Bill Moore, Calif. Franchise Tax Board, Special Procedures

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I took the opportunity to plug your book to those in attendance, as I felt it was a necessary addition to the law library of anyone practicing in the area of bankruptcy and income taxes.

- Mark Segal, Las Vegas, NV

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... have read and reread most of its material with great interest. Please accept my compliments on a thorough and professional treatise.

- Charles L. Pitcock, Esq., Cleveland, Ohio.

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I have used your book often and certainly consider you an authority on discharge of taxes in bankruptcy.

- Kenneth S. Rappaport, Boca Raton, FL

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It is a wonderful desk book.

- Kenneth Klee, Los Angeles, CA.

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I ordered the book last year and I was extremely impressed with it. I have recommended it to a number of attorneys as the only source of its kind I have found. As my present practice I find a large number of clients whose tax problems have been exacerbated by attorneys who fail to understand what your book explains in great detail. Even if an attorney does not practice in the bankruptcy area, he should be acquainted with your book as a service to his own clients.

 

- Don Hairgrove, La Mes, CA.

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. . . so informative and well written that I spent half the night reading it and then the remaining half thinking over the issues. The lack of sleep for one night was a small price to pay for finding the answers to many of my questions.

- Frank Kloster, Santa Maria, CA

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I would like to take a moment to thank you for the work you've done on your book Discharging Taxes in Bankruptcy. I have found it to be an eye-opener, and an indispensible piece of reference work.

-

George Parker, Parker & Assocs., Decatur, GA.

 

 What they say about
King's Guide to Practice Under
The Bankruptcy Reform Act of 2005

"I've utilized several different bankruptcy texts, treatises, etc., and none compare to yours, at least to satisfy my own comfort level.  Thanks for putting such a quality product on the market."

- Steven R. Zweigart, Flemingsburg, Kentucky  July 7 2008

 "I just submitted an online order.  Anything you can do to get it to me as soon as possible would be greatly appreciated. I do not feel comfortable starting to practice under the new law w/out reading your Guide, et al first. Thanks for all you're doing for bk practitioners"

 

- Mark F. Viencek, Rochester, NY

 

"Your Guide has been referred to as "My Bible" many times.   The first guide went everywhere with me for almost a year -- except home to my parents for Christmas. " 

- Barbara Janzen, Leawood, KS

 

"Your books have been a godsend."

 

- Jordan Rappaport, Boca Tatan, FL.

 

"I don't want to fall behind in the new world of BAPCPA and, accordingly, go to the "master" to get my information which is always concise and well written. I, and many other practitioners, sincerely appreciate your publications and efforts."

- Gerald H. Davis, Bankruptcy Trustee, Palm Springs, CA

 

"I really appreciate the great information you provide for us bankruptcy attorneys. As a solo, I don't think I would make it without your resources. Thank you!"

- Alexis Crow, Charlottesville, VA

 

"I will forward you the email that was circulated on our listserve that said we were committing malpractice if we were filing bankruptcies without your guides!"

- Teresa Kidd, Shawnee, KS

 

"I can say that I have seen no other text on the new bankruptcy law that remotely comes close to yours in usability for bankruptcy practitioners."

 

- Gary R. Fraley, Sacramento, CA

 

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"Kings Guide to BAPCPA has proven itself to be the most valuable resource in the office. Although I have taken 4 CLE courses to prep. for 10/17/05 and its aftermath,the book anticipated many of the rulings now coming down."

- William Wolfson, Flemington, NJ

 

"Your materials are essential to the practice of bankruptcy law under BAPCPA."

 

- Robert W. Raley, Bossier City, LA

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"I recommend your book to everyone. It is amazing what you have put in it!"

 - John Bates, New Philadelphia, OH

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"The Guide is remarkably well done and comprehensive.".

 - George Arnold, Evanston, WY

__________

 

"I received it today and began reading immediately. It is a wonderful manual and wish I had the foresight to have ordered it earlier."

​David Zaffina, Hazel Park, MI

__________

"I have been a practicing consumer bankruptcy lawyer for almost 20 years.  When the 2005 BAPCPA law was enacted, I had almost come to the conclusion that my bankruptcy practice was over - the text of the new law is confusing, contradictory and often internally inconsistent.

 

Morgan King's Guide to the 2005 BAPCPA is the main reason I am still in practice. Mr. King's Guide offers a step by step, practical roadmap for practice under the new laws.  I refer to it constantly.  

 

I cannot see how any consumer bankruptcy law practitioner could possibly navigate the minefield of post-BAPCPA practice without this Guide.  It contains checklists, spreadsheets, client handouts and substantive comment.  I frequently teach continuing education seminars about bankruptcy to other lawyers and my first recommendation is to purchase Mr. King's Guide."

 - Jonathan Ginsberg, Atlanta, GA."

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"King's Manual is a must. I read it cover to cover and should probably do it again." -

- David Shaev, N.Y., N.Y.

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"Get Morgan's book on BARF. I wouldn't practice without it."

- Milton D. Jones, Morrow, GA.

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"The book really has saved me."

 -Ron Satija, Austin, TX

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"If you could, please overnight them!  I have heard rave reviews from the folks on the NACBA list and I really could use all the help I can get with this new freaking law.. I have a few post-BARF cases I am starting to work on and I would 'prefer' not to screw up on my first filings."

- Shannon Foster, West Chester, PA

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"I have yet to see anyone but you offer a good guide on how to gear up for the new law. I bought yours and thought it was very good, and have probably sold at least 5-10 via my endorsements and recommendations."

- James Cossitt, Kalispell, MT

 

"I was euphoric on how well the material is presented."

- Wayne Bodow, Syracuse, N.Y.

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"You're getting unanimously wonderful feedback on your book!"

- Jed Berliner, Springfield, MA

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"The book removes the fear . . . you've truly written a map. There's little left to chance. With the checklists and outlines, it's pretty difficult to miss something important and that provides a needed level of comfort."

 

- Adam Schachter, Houston, TX

__________

"Morgan King (not-related and I don't get a commission) has put together an extremely useful guide to practice under the new law. It includes all kinds of wonderful checklists, sample agreements for services, sample handouts and other materials. And pretty much walks you through everything you need to do to be ready to practice under the new law.  It costs a little less than $200 I think and is worth every penny of it. I commend it to your attention."

- Jerry Harper, Topeka, KS

 

"The "Guide to Practice" under BARF is a terrific book, very helpful, lots of checklists and suggestions, flow charts, etc."

 

- D. Jacobs, Chico Ca.

 

"Many thanks. Excellent book. Much more useful than any of the other BAPCPA manuals."

 

- George C. Heck, Old Lyme, CT

 

"The binder has been extremely informative in describing the drastic changes that will soon occur. I am glad that we purchased this binder."

- N. Siegel, Santa Ana, CAƒ

 

"The new laws seemed intimidating before. After reading your guide, I am not too troubled by them."

 

 

- S. Lanin, NY NY

 

"... text seems very comprehensive and helpful."

 

- M. Gunnar, Hilliard, OH

 

"I've found your guide very informative, and only apologize for not letting you know sooner. The guide will be instrumental in helping me prepare for the changes coming."

- S. Flood, Muskogee, OK

 

"I definitely like the stepwise approach to the manual. It makes for a nice progression and it is easy to stay oriented to the material and makes it easy to understand how and where existing practice will change."

G. Heck, New London, Connecticut

 

"Excellent."

- H. Goldstein, Sarasota, FL

 

"... very easy to read and follow."

- D. Patrick, Lynnwood, WA

 

"I received Morgan's book this afternoon in a reasonable time after ordering. The flow charts, checklists, and disclosure statements alone will save my small office a lot of (nonbillable) time as we finalize preparations to deal with the new law. I strongly recommend it to you for your consideration. I have no financial interest in the book."

 

-  Roger Cotner, Grand Haven, MI

 

"I will definitely buy your books as soon as they are available. I have bought some of your books before and I love them!"

- Modesto Lopez, Orlando, Florida

 

"Excellent job!"

- Mark Westbrooks, Phoenix, AZ

 

"I recently attended a panel put on by the chapter 7 trustees. Your presentation of the median income and means tests were much better than what was given to the Trustees."

- Anon. (for obvious reasons)

 

"The Guide to Practice Under the Bankruptcy Reform Act of 2005 has been a tremendous resource.  I am a new attorney who has been doing a self-tutorial on how to practice law in the bankruptcy field.  Your guide has helped me a great deal."

- James Kennedy, Laconia, NH.

 
 
 

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HOTWIRE # 164 DEC. 2019

 

HELD: BRIDGE TOLL IS NOT A "TAX"

 

Am. Trucking Ass'ns v. Alviti (1st Cir. 2019)

 

¶ 2.2 Is It a Tax?

 

This appeal poses the question whether bridge and highway tolls authorized by a Rhode Island statute are taxes within the meaning of the Tax Injunction Act ("TIA").

 

The state statute in question authorizes the Rhode Island Department of Transportation ("RIDOT") to collect from tractor-trailers certain "tolls for the privilege of traveling on Rhode Island bridges" in order to pay "for replacement, reconstruction, maintenance, and operation" of the bridges. R.I. Gen. Laws § 42-13.1-4(a). 

 

The plaintiff trucking entities filed this lawsuit asking the United States District Court for the District of Rhode Island to enjoin the collection of those tolls as violative of the Commerce Clause of the United States Constitution.

 

The district court dismissed the lawsuit for want of jurisdiction under the TIA, which states that "[t]he district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State." 28 U.S.C. § 1341. For the following reasons, we find the TIA's  

prohibition inapplicable to the Rhode Island tolls, and reverse.   

 

" ... we have looked at additional factors in making the tax-fee determination, including whether "[t]he agency places the money in a special fund," San Juan Cellular, 967 F.2d at 686; see also Cumberland Farms, Inc. v. Tax Assessor, 116 F.3d 943, 946 (1st Cir. 1997); Trailer Marine, 977 F.2d at 6, whether collection of the charge is "assigned to the State Tax Assessor," Cumberland Farms, 116 F.3d at 946, whether the requested injunction "poses [a] threat to the central stream of tax revenues," Trailer Marine, 977 F.2d at 6, and whether the enacting entity referred to the charge as a "tax," Cumberland Farms, 116 F.3d at 946. 

 

We therefore agree with the Fourth Circuit's description of San Juan Cellular as "merely provid[ing] flexible and versatile guidance in assessing where a particular charge sits on the tax-fee continuum." Norfolk S. Ry. Co. v. City of Roanoke, 916 F.3d 315, 319 n.2 (4th Cir. 2019); see also id. at 326 (Wynn, J., concurring)."

 

NOTE: The large majority of these factors weigh in favor of deeming the RhodeWorks tolls not to be taxes under the TIA. 

 ____________________________

 

TOPIC: THE "SLEEPING ASSESSMENT" ¶ 2.4(g)(5), (10), ¶ 7.10(b)(12)(vi)

 

COLLECTION DUE PROCESS & SUBSEQUENT STATE TAX ASSESSMENT

 

Succession of Ciervo v. Robinson (La. App. 2019)

 

" ... the IRS reported the adjustments to Mr. Ciervo's 2006-2011 federal income tax liability to the LDR. The Succession did not report the adjustments to Mr. Ciervo's 2006-2011 federal tax liability to the LDR, nor did it file amended state returns for 2006-2011 to reflect the adjustments.

 

        On June 26, 2017, based on the IRS report revealing a substantial discrepancy in federal tax liability between what was reported originally by Mr. Ciervo and what was reported on the amended returns, the LDR assessed additional state income tax owed by Mr. Ciervo for the tax years 2006-2011.

 

These LDR assessments, which included tax, interest, and penalties calculated through July 11, 2017, totaled: $242,523.90 for 2006; $262,439.92 for 2007; $220,296.68 for 2008; $82,566.10 for 2009; $47,551.74 for 2010; and $2,612.18 for 2011.

 

ARTICLE: Succession of Ciervo v. Robinson  - Robert J. DavidGainsburgh, Benjamin, David,Meunier & Warshauer, L.L.C

 _____________________

 

COLLECTION DUE PROCESS, ATTACKING TAX LIENS, DISCHARGING TAXES ¶ 2.6(d), ¶ 5.7

 

HELD: IRS LIEN WAS ALLOWED DESPITE THREAT TO TAXPAYER'S EMPLOYMENT.  

 

Brown v. Comm'r (T.C. 2019)     

 

Petitioner filed Federal income tax returns for 2007, 2010, 2011, 2012, and 2014 (years in question) but failed to pay the full amounts of tax shown as due on those returns. The IRS assessed the tax plus interest and additions to tax for failure to pay.

 

As of September 2016, petitioner's outstanding liabilities for the five years in question totaled $18,533. He also had outstanding liabilities for 2006 and 2015, bringing his aggregate unpaid Federal income tax liability to $35,436.

 

In an effort to address these unpaid liabilities petitioner sought an installment agreement. In September 2016 the IRS enrolled him in a partial payment installment agreement (PPIA) calling for payments of $300 per month. But the IRS determined that the filing of an NFTL was necessary because petitioner's unpaid balance of assessments exceeded $10,000. See Internal Revenue Manual, Page 3 (IRM) pt. 5.12.2.6(1) (Oct. 14, 2013). The IRS accordingly filed an NFTL covering the five years in question.

 

On October 4, 2016, the IRS sent petitioner a Letter 3172, Notice of Federal Tax Lien Filing and Your Right to a Hearing. Petitioner thereafter spoke with an official at the IRS Automated Collection Services (ACS) and represented that he would lose his job if the IRS did not withdraw the NFTL.

 

The ACS official had no authority to withdraw the NFTL, but on the basis of petitioner's representation she said that she would recommend withdrawal. Petitioner subsequently received from the IRS a blank Form 12277, Application for Withdrawal of Filed Form 668(Y), Notice of Federal Tax Lien.

______________________

TRAPS FOR THE UNWARY 

    

FROM MORGAN KING'S

 

CHECKLIST OF 51 ISSUES

that may arise 

IN TAX DISCHARGE CASES 

 

References "¶" refer to the corresponding section of King's Discharging Taxes in Consumer Bankruptcy  Cases. TaxPublishing.com

BankruptcyBooks.com 

 

√   TRAP # 44.  "Equitable tolling." A prior bankruptcy may toll the two-year period prescribed at § 523(a)(1)(B)(ii). Putnam v. Internal Revenue Serv. (In re Putnam), 503 B.R. 656 (Bankr. E.D.  N.C., 2014); Ollie-Barnes v.  Internal Revenue Serv. (In re        Ollie-Barnes) (Bankr. M.D.N.C., 2014); In re Spinks, 591 B.R. 113 (Bankr. S.D. Ga., 2018).           

 

Looking at the basics of tax discharge we know that there are "time rules" that, in part, govern tax discharge.

 

These are: the three-year rule per 11 U.S.C. § 507(a)(8)(A)(i), the 240-day rule per 11 U.S.C. § 507(a)(8)(A)(ii), and the 2-year rule per § 523(a)(1)(B)(ii). 

We also know that the 3-year rule and the 240-day rule may be suspended (tolled) by certain events that may stretch out the time, e.g., an offer in compromise, a collection due process appeal, and several other events. The tolling is expressly provided by the Code, namely, 11 U.S.C. 507 11 U.S.C. § 507(a)(1)(G).

 

But, nowhere in the Code will you find language that any event tolls or suspends the running of the 2-year rule, which is that the taxpayer must have filed a valid tax return more than 2 years before the bankruptcy is filed.

 

So, it is often said, nothing tolls the 2-year period.

 

But a short line of cases have held that the 2-year period may be tolled or suspended based on the theory of "equitable tolling." In a nutshell, this theory holds that preventing the tax collector from collecting caused by the debtor's conduct may justify stopping the clock on the 2-years where failure to do so would deny the tax collector a fair shot at collecting.

 

In other words, if the debtor's conduct causes a delay in collecting, it may justify tolling. The facts of the cases suggest that where the debtor's conduct somehow rises to the level of tax evasion or similar conduct, the 2-year period may be tolled.

 

These are fact-intensive issues, and most opinions do not go that far.

 

King's Discharging Taxes in Consumer Bankruptcy Cases,  See ¶ 2.9

WHAT THEY SAY ABOUT OUR

COURSES, SEMINARS, AND WEBINARS

"I recently completed Morgan King’s Forms And Filings Course. This was the first time I’d ever taken a Forms and Filings course. As I am new to Bankruptcy, I wondered how the format and instruction would be on Zoom.

 

"The content and organization was well thought out and very informative. The instruction was excellent, and I can’t imagine a better way of walking students through such an extensive amount of information remotely.

 

"Really well done. Thank you so much Morgan!"*

 

                 - Madeline McIntosh, Esq. Texas Bar  

 

 

Morgan King often appears at NACBA as the guru we respect for discharging tax debts. He also has a seminar with other experts on student loans. I can't praise Morgan King's training enough for being complete on the small things that you need to know about discharging tax debts.

- Nick Thompson, Esq. Kentucky Bar

 

I have been to many of  your seminars.  I figure you are great and you have taught me more than any other course or seminar.

 

I will definitely want to take your 3-day course over.   I even have a few ugly IRS cases to review at seminar.

 

- Pam Marchese, Esq. Ca Bar 05/16/19

I wasn't able to be on the webinar, but have only heard great things about it.

- Ed. Boltz, Esq. current President of NACBA

 

Morgan King's Bankruptcy Academy offers an absolutely superb bankruptcy course that is second to none. Morgan explains bankruptcy in a detailed concise format that is easily understandable.

 

As an attorney, I deeply appreciate Morgan's years of experience and professionalism, which allows him to fully articulate the nuts and bolts of a Bankruptcy practice. Morgan's course is vital for every bankruptcy attorney who aspires to be the best in his/her field."

- Kelly Finley Nebiolini Esq., California

"Now I can use these deadlines in everyday practice and understand what it means to file before the automatic stay runs out etc without looking like a deer in the headlights."

- Rebecca Watters, paralegal, Orlando, Florida

"I feel so much more confident about taking on bankruptcy cases than before I started the course!"

- Jennifer Filla Esq., Colorado Springs, CO

"Without a doubt the most useful legal course I have taken. Find that I am still a bit overwhelmed, difference is I know what needs to get done and in what order. I am very appreciative of the response to my questions and issues along the way. Well done Mr. King."

- Gerald E. Roque
Houston, TX

"Outstanding! There are no other courses like this out there!"

- Michael Alfano, Esq.Exeter NH

" ... I am really enjoying the course and wish I would have spent the money on this two years ago when I started rather than various other courses I wasted my money on."

- Chandra Apperson, Esq. Monterey, CA

"Outstanding! Content - great! Visuals are outstanding! Test is good learning device for recall."

- Carol Cross Stone Esq., Long View, TX

"My firm, consisting of myself and my paralegal, decided to do bankruptcies when it became clear that there was a pressing need that was not being served in our community. 

We bought the software and read the books, but then we got our first clients and we went to fill out the petitions and we were lost. Your class saved the day! We filed our first case ever today, a fairly complicated 13, and we did so with confidence thanks to the knowledge we gained from the Bankruptcy Academy. 

 

Your classes took the complicated mass of bankruptcy law and broke it down into manageable chunks."

 - Justin Kallal, Jackson, WY

 CONTENT RICH, EASY TO UNDERSTAND

Every piece of information has been content rich, easy to understand and has allowed me to take the information and apply it to the bankruptcy petitions I am working on right now. 

Understanding the law behind the Bankruptcy Code rules and regulations make a huge difference when preparing petitions. Having the outlines and the practical examples, which take yo u through each schedule step-by-step,  has been invaluable.  

 

I'm stressed because there is lot's I have yet to learn but the course materials have made my life easier.   I really want to get to the hands-on videos.

Jeannie, you did a GREAT JOB putting the course material together with Attorney King.  I am so proud of you!  I have recommended this course to several other VBA's I have spoken with."

- Vivian Little
Certified Bankruptcy Assistant, Chicago, IL

A LOT OF TRAINING!

"Compared to the various seminars / webinars offered by other organizations, the price is a bargain for the large number of hours of training and the additional resources. No matter how you look at it, 12 hours is a lot of training."

- Louise Hurwitz,
Certified NSVBA

 

I LIKE YOUR COURSES!

"I like your courses so much I'[m thinking of signing up all my company's staff for the group class."

- Yordi Fraser, Certified Paralegal, Stamford, CT

"I found the first course very helpful. Although I am not the attorney, I am to be taking on a larger role of managing the BK division at the law firm and due to the number of clients I see on a daily basis, this is something that I find helpful."

- Rob, Sobti Law Group, Beaumont, Orange, and Cornoa, CA

This is a wonderful course!

- Arthur W. Chettle
San Diego, CA

The course has exceeded my expectations so far!!! I already told another attorney about the course.

- Yordi Fraser
Stamford, CT

just finished the first three hours of your on-line course "Discharging  Taxes In Bankruptcy." Also, I finished the first hour of the Certification course.

I am extremely pleased with the content of the course and the way you have presented it. The detailed analysis that you provided in the Discharging Taxes course was absolutely outstanding!! The visual aids were well constructed and very helpful. Next year I will be teaching a course on " Tax Aspects of Bankruptcy" and I intend to use your course and materials for 20 to 25% of this new course that I will be teaching here at the UMKC law school.

I intend to spread the word about the Bankruptcy Academy. I find the content to be invaluable---it is as must for those who intend to practice in this area.

- Professor Ed Hood, University of Missouri-Kansas City School of Law

 

Consumer bankruptcy lawyers all know Morgan King and his Bankruptcy Academy. For years, Morgan has honed his knowledge of discharging taxes in bankruptcy - and his studies have paid off. Morgan's not only one of the smartest tax/bankruptcy guys out there, but he's an incredible teacher. If you've heard him speak at the NACBA conferences you already know what I'm talking about.

- Bankruptcy attorney Jay Fleischman, Brooklyn, NY

This is a must program! In fact, it was so good I'm seeing it again!

- Bankruptcy attorney Antonio Villeda, McAllen,Texas

Both Amy and I thoroughly enjoyed your seminar.  It's the only one I've found that actually allows me to learn something in my chosen field.

- Bankruptcy attorneys N. D.,

Deininger & Wingfield, P.A., Little Rock, Arkansas

I thought I knew the subject. But when I took the Academy I realized how superficial my understanding had been. I left with a new confidence and a new competence I could not have gotten anywhere else.

Bankruptcy attorney Marlow Preston, Austin, Texas

I appreciate the invaluable information you have given other attorneys. As a small (2 person office) it is very difficult to venture outside your comfort zone of area of practice. I cannot thank you enough.

- Bankruptcy attorney Bob Ellis, Columbus Ohio

It was great! I took both factual information and a real sense of confidence from the week. If you plan any seminars regarding other topics, I will be there.

- Bankruptcy attorney Brian Zeiden, Los Angeles, California

This course is a MUST for consumer bankruptcy practitioners. Morgan and his expert speakers and the materials presented, provide excellent guidance and hands-on practical tips and advice that are immediately useful.

- Ellen Stone, Managing Attorney, Law Offices of John Ventura, Brownsville, Texas

I have not seen anyone that provides more information and expertise than you. I am always very impressed with the extent of work, energy and expertise you bring to your seminars.

 

- Bankruptcy attorney Marguerite Kirk, Bedford, TX

. . . the course was excellent and would take it again and bring my associate.  Of course we would prefer to have it in the East, but I did enjoy San Francisco and the restaurant that you recommended.

 

- Bankruptcy attorney Donald G. Koch, New York, NY.

I really enjoyed the program. I learned some new things and it reinforced what I had already learned from your web-site. One thing I'm excited about is that it opened up a prospective market for me that I had not yet recognized. I plan to market my services as a consultant to tax and bankruptcy attorneys in my state. Reading transcripts can be quite complicated for the inexperienced and preparing delinquent returns may sometimes be needed. With your book as a reference I will feel comfortable and conversant when speaking to other professionals.

Thanks for doing what you do. There's a tremendous need for it. I know of several atty's in my area who don't know (enough) about tax discharge. More EA's who practice representation need this knowledge as well. Our clients aren't effectively served if we don't present all their options....and know a bad attorney when we see one.

- Enrolled Agent Lisa Sexton, Carlsbad NM

I just wanted to let you know that I thought your BK academy was terrific and very informative.

- Bankruptcy attorney Martin A. Berger, Hilo, HI

I love your programs. Thanks for supporting the Debtors' bar over the years.

 

- Bankruptcy attorney Steve Berken, Denver, CO

I've enjoyed being in your seminars in the past and have used the valuable knowledge you've imparted from them both in my everyday work and in the books I've contributed ...

- Allan Rosenthal, paralegal, San Francisco CA

 

Morgan King's Bankruptcy Academy offers an absolutely superb bankruptcy course that is second to none. Morgan explains bankruptcy in a detailed concise format that is easily understandable. As an attorney, I deeply appreciate Morgan's years of experience and professionalism, which allows him to fully articulate the nuts and bolts of a Bankruptcy practice. Morgan's course is vital for every bankruptcy attorney who aspires to be the best in his/her field."

- Kelly Finley Nebiolini Esq., California

"Now I can use these deadlines in everyday practice and understand what it means to file before the automatic stay runs out etc without looking like a deer in the headlights."

- Rebecca Watters, paralegal, Orlando, Florida

"I feel so much more confident about taking on bankruptcy cases than before I started the course!"

Jennifer Filla Esq., Colorado Springs, CO

"Without a doubt the most useful legal course I have taken. Find that I am still a bit overwhelmed, difference is I know what needs to get done and in what order. I am very appreciative of the response to my questions and issues along the way. Well done Mr. King."

- Gerald E. Roque, Houston, TX

"Outstanding! There are no other courses like this out there!"

- Michael Alfano, Esq.Exeter NH

" ... I am really enjoying the course and wish I would have spent the money on this two years ago when I started rather than various other courses I wasted my money on."

- Chandra Apperson, Esq. Monterey, CA

"Outstanding! Content - great! Visuals are outstanding! Test is good learning device for recall."

- Carol Cross Stone Esq., Long View, TX

"My firm, consisting of myself and my paralegal, decided to do bankruptcies when it became clear that there was a pressing need that was not being served in our community. 

We bought the software and read the books, but then we got our first clients and we went to fill out the petitions and we were lost. 

Your class saved the day! We filed our first case ever today, a fairly complicated 13, and we did so with confidence thanks to the knowledge we gained from the Bankruptcy Academy. 

Your classes took the complicated mass of bankruptcy law and broke it down into manageable chunks."

 - Justin Kallal, Jackson, WY

 CONTENT RICH, EASY TO UNDERSTAND

Every piece of information has been content rich, easy to understand and has allowed me to take the information and apply it to the bankruptcy petitions I am working on right now. 

Understanding the law behind the Bankruptcy Code rules and regulations make a huge difference when preparing petitions. Having the outlines and the practical examples, which take yo u through each schedule step-by-step,  has been invaluable.  

I'm stressed because there is lot's I have yet to learn but the course materials have made my life easier. I really want to get to the hands-on videos.

 

Jeannie, you did a GREAT JOB putting the course material together with Attorney King.  I am so proud of you!  I have recommended this course to several other VBA's I have spoken with."

- Vivian Little
Certified Bankruptcy Assistant, Chicago, IL

A LOT OF TRAINING!

"Compared to the various seminars / webinars offered by other organizations, the price is a bargain for the large number of hours of training and the additional resources. No matter how you look at it, 12 hours is a lot of training."

Louise Hurwitz,
Certified NSVBA

I LIKE YOUR COURSES!

"I like your courses so much I'[m thinking of signing up all my company's staff for the group class."

Yordi Fraser, Certified Paralegal, Stamford, CT

"I found the first course very helpful. Although I am not the attorney, I am to be taking on a larger role of managing the BK division at the law firm and due to the number of clients I see on a daily basis, this is something that I find helpful."

Rob, Sobti Law Group, Beaumont, Orange, and Cornoa, CA

This is a wonderful course!

Arthur W. Chettle
San Diego, CA

The course has exceeded my expectations so far!!! I already told another attorney about the course.

- Yordi Fraser
Stamford, CT

just finished the first three hours of your on-line course "Discharging  Taxes In Bankruptcy." Also, I finished the first hour of the Certification course.

I am extremely pleased with the content of the course and the way you have presented it. The detailed analysis that you provided in the Discharging Taxes course was absolutely outstanding!! The visual aids were well constructed and very helpful. Next year I will be teaching a course on " Tax Aspects of Bankruptcy" and I intend to use your course and materials for 20 to 25% of this new course that I will be teaching here at the UMKC law school.

I intend to spread the word about the Bankruptcy Academy. I find the content to be invaluable---it is as must for those who intend to practice in this area.

- Professor Ed Hood, University of Missouri-Kansas City School of Law

Consumer bankruptcy lawyers all know Morgan King and his Bankruptcy Academy. For years, Morgan has honed his knowledge of discharging taxes in bankruptcy - and his studies have paid off. Morgan's not only one of the smartest tax/bankruptcy guys out there, but he's an incredible teacher. If you've heard him speak at the NACBA conferences you already know what I'm talking about.

- Bankruptcy attorney Jay Fleischman, Brooklyn, NY

This is a must program! In fact, it was so good I'm seeing it again!

- Bankruptcy attorney Antonio Villeda, McAllen,Texas

Both Amy and I thoroughly enjoyed your seminar.  It's the only one I've found that actually allows me to learn something in my chosen field.

 

- Bankruptcy attorneys N. D., Deininger & Wingfield, P.A., Little Rock, Arkansas

I thought I knew the subject. But when I took the Academy I realized how superficial my understanding had been. I left with a new confidence and a new competence I could not have gotten anywhere else.

Bankruptcy attorney Marlow Preston, Austin, Texas

I appreciate the invaluable information you have given other attorneys. As a small (2 person office) it is very difficult to venture outside your comfort zone of area of practice. I cannot thank you enough.

- Bankruptcy attorney Bob Ellis, Columbus Ohio

It was great! I took both factual information and a real sense of confidence from the week. If you plan any seminars regarding other topics, I will be there.

 

- Bankruptcy attorney Brian Zeiden, Los Angeles, California

This course is a MUST for consumer bankruptcy practitioners. Morgan and his expert speakers and the materials presented, provide excellent guidance and hands-on practical tips and advice that are immediately useful.

- Ellen Stone, Managing Attorney, Law Offices of John Ventura, Brownsville, Texas

I have not seen anyone that provides more information and expertise than you. I am always very impressed with the extent of work, energy and expertise you bring to your seminars.

 

- Bankruptcy attorney Marguerite Kirk, Bedford, TX

. . . the course was excellent and would take it again and bring my associate.  Of course we would prefer to have it in the East, but I did enjoy San Francisco and the restaurant that you recommended.

 

- Bankruptcy attorney Donald G. Koch, New York, NY.

I really enjoyed the program. I learned some new things and it reinforced what I had already learned from your web-site. One thing I'm excited about is that it opened up a prospective market for me that I had not yet recognized. I plan to market my services as a consultant to tax and bankruptcy attorneys in my state. Reading transcripts can be quite complicated for the inexperienced and preparing delinquent returns may sometimes be needed. With your book as a reference I will feel comfortable and conversant when speaking to other professionals.

Thanks for doing what you do. There's a tremendous need for it. I know of several atty's in my area who don't know (enough) about tax discharge. More EA's who practice representation need this knowledge as well. Our clients aren't effectively served if we don't present all their options....and know a bad attorney when we see one.

- Enrolled Agent Lisa Sexton, Carlsbad NM

I just wanted to let you know that I thought your BK academy was terrific and very informative.

 

- Bankruptcy attorney Martin A. Berger, Hilo, HI

 

I love your programs. Thanks for supporting the Debtors' bar over the years.

 

- Bankruptcy attorney Steve Berken, Denver, CO

 

I've enjoyed being in your seminars in the past and have used the valuable knowledge you've imparted from them both in my everyday work and in the books I've contributed ...

 

- Allan Rosenthal, paralegal, San Francisco CA

© MORGAN D. KING 2016-2020 Technical web advisor Douglas Morrison

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