In Re Jehan-Das, Inc., Debtor. Jehan-Das, Inc. v. United States of America, and Internal Revenue Service

FAGG, Circuit Judge.

The sole issue presented on appeal is whether Jehan-Das, Inc.’s payment of the proceeds from its liquidated bankruptcy estate to the Internal Revenue Service (IRS) in partial satisfaction of the IRS’s administrative claim for postpetition taxes is voluntary or involuntary. The bankruptcy court concluded the payment is involuntary. We affirm.

The controlling facts are undisputed. After Jehan-Das filed Chapter 11 bankruptcy in 1981, it incurred a substantial tax liability, including, trust fund taxes for employees’ personal income taxes and social security taxes. See 26…