Summary:
During Ms. Boykin’s Chapter 13 case, the bankruptcy court held that the claim by the United States arising under the Affordable Care Act ("Obamacare") out of her failure to obtain health insurance was a non-priority penalty and not a tax. While this appeal by the government was pending, Ms. Boykin voluntarily converted her case to Chapter 7, in which all parties agreed there would be no insufficient assets for any distribution to creditors.