In Re: James Curtis Palmer, Debtor. James Curtis Palmer v. United States of America, Internal Revenue Service

OPINION

COLE, Circuit Judge.

Plaintiff-Appellant James Curtis Palmer, a Chapter 7 debtor in bankruptcy, appeals the decision of the Bankruptcy Appellate Panel of the Sixth Circuit (“BAP”), which reversed the bankruptcy court’s holding that Palmer’s 1991 and 1992 tax debts are dischargeable. See Palmer v. Internal Revenue Serv. (In re Palmer), 228 B.R. 880 (6th Cir. BAP 1999). For the reasons discussed below, we REVERSE the decision of the BAP and AFFIRM the holding of the bankruptcy court.

I. BACKGROUND

The parties do not dispute the relevant facts of this case. Palmer filed a Chapter 13…