BANKRUPTCY LAW: Late, post-assessment tax returns were “tax returns” within the meaning of 11 USC Sec. 523 (a)(1)(B), and debtor’s old tax debt could be discharged pursuant to satisfaction of other statutory requirements. (In re Martin, adversary action vs. IRS) From NACBA: In finding that the Martins filed a “return” and that their tax debt was therefore dischargeable, the bankruptcy court applied the test set forth in Beard v. Comm’r, 82 T.C. 766, 774–79 (1984), aff’d 793 F.2d 139 (U.S. Sixth Circuit Court of Appeal, 1986)

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