Florida Department of Revenue v. Piccadilly Cafeterias, Inc.

Summary

The Court, in an opinion by Justice Thomas, held that 11 U.S.C. § 1146(a)'s stamp-tax exemption applies only to transfers made pursuant to an already confirmed Chapter 11 plan. Because Piccadilly transferred its assets before confirmation, the Court reversed the Eleventh Circuit's judgment and remanded. The Court relied on the statutory language, the provision's placement among postconfirmation matters, and the canon requiring a narrow construction of exemptions from state taxation. Justice Breyer, joined by Justice Stevens, dissented, reasoning that the language was ambiguous and that excluding preconfirmation transfers frustrated Congress's purposes of preserving going concerns and maximizing assets available to creditors.