Supreme Court of the United States
Florida Department of Revenue v. Piccadilly Cafeterias, Inc.
June 16, 2008554 U.S. 33
Summary
The Court held that 11 U.S.C. § 1146(a) stamp-tax exemption applies only to asset transfers made after a Chapter 11 plan is confirmed. Textual analysis of "under a plan confirmed" and the placement within the "POSTCONFIRMATION MATTERS" subchapter support this, along with the canon requiring clear expression for exemptions from state taxation. Justice Breyer, dissenting, argued the statute is ambiguous and the provision's purpose supports exempting pre-confirmation transfers necessary for reorganization.