Many practitioners know that certain types of tax debt are not discharged in an individual debtor’s bankruptcy case. But there are classes of tax debt that may be discharged. For example, income tax debt not excepted under Bankruptcy Code section 523(a)(1) may be discharged. One exception in section 523 is for tax debt for which a tax return was not filed or given. This can often come up in an individual bankruptcy case where the debtor has failed to file tax returns before the bankruptcy case. But what happens to the tax debt if the debtor filed the return late?