When the Bankruptcy Code was changed in 2005, significant changes were made to the tax return filing requirements for Chapter 7 and Chapter 13 consumer bankruptcy debtors. The changes increased the need for a Debtor and their counsel to review tax filing information before filing a Chapter 7 or Chapter 13 consumer bankruptcy case. A recent Chapter 13 case in which I represented a debtor in New Jersey provides a good example of the often complicated nature of the bankruptcy code as it relates to tax filings and how it affects a case.