Excluded pre-resolution tax claims and evidence gathering cannot justify reassessment of a corporate debtor after an approved insolvency resolution.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Pre-approval income tax claims omitted from an approved resolution plan stand extinguished, and the plan binds government creditors. The Insolvency and Bankruptcy Code overrides inconsistent Income Tax Act provisions, preventing reassessment to pursue those claims. Refusal to waive statutory obligations in the plan approval order does not preserve an excluded claim. Reassessment provisions address income that has escaped assessment and cannot be used merely to collect evidence against former management or third parties. Lawful action against them may be pursued under separate statutory powers.....