United States v. Warfield

CourtDistrict Court, D. Arizona
DecidedApril 19, 2021
Docket3:20-cv-08204
StatusUnknown

This text of United States v. Warfield (United States v. Warfield) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Warfield, (D. Ariz. 2021).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 United States of America, No. CV-20-08204-PCT-DWL

10 Appellant, ORDER

11 v.

12 Lawrence J. Warfield, et al.,

13 Appellees. 14 15 INTRODUCTION 16 In 2015, Sandra J. Tillman (“Debtor”) purchased a house valued at $475,000 in 17 Prescott, Arizona. Bank of America (“BofA”) and the Internal Revenue Service (“IRS”) 18 held secured claims on the house arising from, respectively, a mortgage and a pre- 19 bankruptcy tax penalty lien. 20 In 2019, Debtor filed a petition for Chapter 7 bankruptcy and claimed a $150,000 21 homestead exemption in the house under Arizona law. The Trustee instituted an adversary 22 proceeding to avoid the IRS’s tax lien and preserve the lien for the benefit of the bankruptcy 23 estate. The government and Debtor objected, arguing that the Trustee could not avoid the 24 lien or, in the alternative, that the avoided lien could not be preserved for the benefit of the 25 estate and, instead, should fall within Debtor’s homestead exemption and be preserved for 26 her benefit. The Trustee filed a motion for summary judgment, which the government and 27 Debtor opposed. The bankruptcy court, after allowing supplemental briefing and holding 28 oral argument, issued a detailed order granting summary judgment to the Trustee. 1 The government now seeks review of the bankruptcy court’s order. For reasons 2 explained below, that order is affirmed. 3 BACKGROUND ON BANKRUPTCY CODE PROVISIONS 4 I. Exemptions 5 “An estate in bankruptcy consists of all the interests in property, legal and equitable, 6 possessed by the debtor at the time of filing, as well as those interests recovered or 7 recoverable through transfer and lien avoidance provisions.” Owen v. Owen, 500 U.S. 305, 8 308 (1991), superseded by statute on other grounds as recognized in In re Ehlen, 202 B.R. 9 742, 744-45 (Bankr. W.D. Wis. 1996). See also 11 U.S.C. § 541. In some circumstances, 10 however, a debtor may exempt property, which serves to remove it from the bankruptcy 11 estate. In re Heintz, 198 B.R. 581, 585 (9th Cir. BAP 1996). In other words, the debtor 12 generally retains exempt property, and it cannot be used to satisfy the claims of unsecured 13 creditors in the bankruptcy proceeding. Owen, 500 U.S. at 308 (“An exemption is an 14 interest withdrawn from the estate (and hence from the creditors) for the benefit of the 15 debtor.”); Heintz, 198 B.R. at 585 (“Once property is exempted, its status as property of 16 the estate is terminated and the property is ultimately revested in the debtor.”). “The federal 17 exemptions in the Bankruptcy Code were enacted to ensure that a debtor coming out of the 18 bankruptcy process retains sufficient possessions to obtain a fresh start.” In re Butcher, 19 189 B.R. 357, 369 (D. Md. 1995). See also Matter of Hahn, 5 B.R. 242, 244 (Bankr. S.D. 20 Iowa 1980) (the “basic purposes for exemption laws” are to “provide a debtor enough 21 money to survive,” to “protect his dignity and his cultural and religious identity,” to “afford 22 a means of financial rehabilitation,” to “protect the family unit from impoverishment,” and 23 to “spread the burden of the debtor’s support from society to his creditors”). 24 Although § 522 of the Bankruptcy Code enumerates the exemptions available to a 25 debtor in bankruptcy, § 522(b)(1) authorizes state legislatures to “opt out” of the § 522 26 exemption scheme and provide their own exemption schemes. “If a State opts out, then its 27 debtors are limited to the exemptions provided by state law.” Owen, 500 U.S. at 308. 28 Arizona, like many other states, has opted out of the § 522 exemptions and provides its 1 own to Arizona residents. A.R.S. § 33-1133(B). Among other things, Arizona provides a 2 homestead exemption that permits a resident to exempt her “interest in real property . . . in 3 which [she] resides,” up to $150,000 “in value.” Id. § 33-1101(A)(1). 4 Section 522 also “places limitations on a debtor’s ability to shield exempted 5 property from liability for pre-petition tax debts.” In re Wright, 156 B.R. 549, 554 (N.D. 6 Ill. 1992). For example, “exempted property remains liable for certain nondischargeable 7 pre-petition tax debts.” Id. A “properly filed tax lien is unavoidable in bankruptcy; 8 exempted property on which the IRS has properly filed a tax lien remains liable for any 9 debt secured by that lien.” Id. (collecting cases). See also 11 U.S.C. § 522(c)(2)(B) 10 (“[P]roperty exempted under this section is not liable during or after the case for any debt 11 of the debtor that arose . . . before the commencement of the case, except . . . a debt secured 12 by a lien that is . . . a tax lien, notice of which is properly filed.”). 13 II. Avoidance 14 Under § 724(a) of the Bankruptcy Code, a trustee may “avoid” a “lien that secures 15 a claim of a kind specified in section 726(a)(4),” such as a lien for pre-petition tax 16 penalties.1 When a trustee avoids a lien, it is essentially transformed into an unsecured 17 claim, which maintains a lower priority in the distribution of bankruptcy estate assets. See, 18 e.g., In re Gill, 574 B.R. 709, 717 (9th Cir. BAP 2017) (“[I]t is clear by operation of 19 §§ 724(a) and 726(a)(4) that a penalty which is secured by a tax lien is automatically 20 demoted in a chapter 7 case from the highest priority to the lowest priority, payable only 21 after general unsecured creditors are paid in full.”); 6 Collier on Bankruptcy ¶ 724.02[6] 22 (“In enacting section 724(a), . . . Congress made a policy determination that payment of 23 claims for penalties or punitive damages should be subordinated to payment of general 24 unsecured claims.”). 25 1 Section 726(a)(4) concerns, among other things, “payment of any allowed claim, 26 whether secured or unsecured, for any fine, penalty, or forfeiture.” A lien for pre-petition tax penalties appears to fall within the bounds of § 726(a)(4). See, e.g., In re Hutchinson, 27 579 B.R. 860, 862 (Bankr. E.D. Cal. 2018) (“Section 726(a)(4) encompasses a broad spectrum of fines, penalties, and forfeitures, including tax penalties.”); 6 Collier on 28 Bankruptcy ¶ 726.02[4] (16th ed. 2012) (“[S]ection 726(a)(4) includes prepetition tax penalties if they are not compensation for actual pecuniary loss.”). 1 III. Preservation 2 Under § 551 of the Bankruptcy Code, “[a]ny transfer avoided under section 3 522 . . . or 724(a) . . . is preserved for the benefit of the estate but only with respect to 4 property of the estate.”2 In essence, this permits the trustee to recover the value of the 5 avoided claim and use it to “increase the assets of the estate for distribution to creditors.” 6 Heintz, 198 B.R. at 585. See also 11 U.S.C. § 541(a)(4) (“[The bankruptcy] estate is 7 comprised of . . . [a]ny interest in property preserved for the benefit of . . . the estate under 8 section . . . 551 . . . .”). Section 551 “serves as a ‘follow-up’ provision explaining how 9 assets and property avoided under other Code provisions should be handled.” Jurista v. 10 Amerinox Processing, Inc., 492 B.R. 707, 774 (D.N.J. 2013). 11 “Once a trustee recovers an asset for the estate through one of the transfer or lien 12 avoidance provisions, § 551 automatically preserves the asset for the estate.” Heintz, 198 13 B.R. at 584. See also In re Trible, 290 B.R. 838, 844 (Bankr. D. Kan. 2003) (“As this 14 Court reads § 551, upon avoidance of [the] lien . . .

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In Re Butcher
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United States v. Warfield, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-warfield-azd-2021.