Case Summary:
Chase Bank commenced this action for nondischargeability under § 523(a)(14) against the Defendant. The Defendant had charged a tax deposit to the IRS on his Chase Bank credit card. The deposit was not for the payment of tax, but rather served as a deposit if the IRS later determined that the Defendant owed income tax for tax year 2009. Subsequently, the Defendant received a refund from the IRS for an amount in excess of the initial deposit. Because Chase presented no evidence that the Defendant actually had a tax liability for 2009, Chase could not establish that the deposit was used to pay a “tax owed” to the IRS under § 523(a)(14). Accordingly, the Court dismissed Chase’s complaint and rendered the debt discharged.

Statute/Rule References:
11 U.S.C. § 523(a)(1) -- Nondischargeability - Taxes
11 U.S.C. § 523(a)(8)(A)(i) 
11 U.S.C. § 523(a)(14) -- Nondischargeability - Marital Obligations
11 U.S.C. § 523(a)(15) -- Nondischargeability - Marital Obligations

Key Terms:
Deposit Paid for Income Tax
Income Tax
Non-Dischargeable Tax
Taxes - Dischargeability