U.S. Sup. Ct.
10-875
Chapter 12 of the Bankruptcy Code allows farmer debtors with regular annual income to adjust their debts subject to a reorganization plan. The plan must provide for full payment of priority claims. 11 U. S. C. §1222(a)(2). Under §1222(a)(2)(A), however, certain governmental claims arising from the disposition of farm assets are stripped of priority status and downgraded to general, unsecured claims that are dischargeable after less than full payment. That exception applies only to claims entitled to priority under [11 U. S. C. §507] in the first place. As relevant here, §507(a)(2) covers administrative expenses allowed under §503(b), which includes any tax … incurred by the estate. §503(b)(B)(i).
