Supreme Court of the United States

Bruning v. United States

March 23, 1964376 U.S. 358

Summary

Chief Justice Warren delivered the Court's opinion affirming the Ninth Circuit. The Court held that post-petition interest on an unpaid federal tax debt excepted from discharge remains the debtor's personal liability and may be collected from assets acquired after bankruptcy. The rule disallowing post-petition interest against the bankruptcy estate concerns equitable distribution and administrative convenience, not the debtor's continuing personal liability. The Government's filing of a bankruptcy claim did not limit its right to collect that interest under § 6873(a) of the Internal Revenue Code. There were no separate opinions.

Holding

  • Personal liability for post-petition interest on a nondischargeable tax debt.. Post-petition interest on an unpaid tax debt excepted from discharge under § 17 remains a personal liability of the debtor after bankruptcy and may be recovered from subsequently acquired assets.
  • Effect of filing a bankruptcy claim on the Government's right to continuing interest.. Section 6873(a) does not limit the Government's right to continuing interest on an undischarged and unpaid tax liability merely because the Government filed a claim in bankruptcy.

Docket 423

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