Florida Department of Revenue v. Piccadilly Cafeterias, Inc.

The Bankruptcy Code provides a stamp-tax exemption for any asset transfer “under a plan confirmed under [Chapter 11]” of the Code. 11 U. S. C. § 1146(a) (2000 ed., Supp. V). Respondent Piccadilly Cafeterias, Inc., was granted an exemption for assets transferred after it had filed for bankruptcy but before its Chapter 11 plan was submitted to, and confirmed by, the Bankruptcy Court. Petitioner, the Florida Department of Revenue, seeks reversal of the decision of *36the Court of Appeals upholding the exemption for Piccadilly’s asset transfer. Because we hold that § 1146(a)’s stamp-tax exemption…