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Lynwood and Brenda Hall filed for Chapter 12 bankruptcy and were forced to sell their family farm for $960,000 to settle their bankruptcy debts. That sale brought about capital gains taxes of $26,000. The Halls wanted the taxes treated as part of the bankruptcy, paying part of it and having the court discharge the rest. The IRS objected to that plan, saying all of the taxes must be paid. The U.S. Court of Appeals for the Ninth Circuit agreed, ruling that the Halls' had to pay federal income tax on the gain from the sale of their farm during bankruptcy proceedings.

Does 11 U.S.C. 1222(a)(2)(A) authorize the bankruptcy court to treat as a dischargeable non-priority claim a federal tax debt arising out of the debtor's post-petition sale of a farm asset?