UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

IN RE:

LORENZO ANDREW ALLEN,

Debtor.

___________________________________/

CASE NO.: 22-10014-SMG

CHAPTER 13

UNITED STATES OF AMERICA’S

OBJECTION TO CONFIRMATION

The United States of America, by and through its undersigned Assistant United States 

Attorney, on behalf of the Internal Revenue Service (“IRS”), hereby objects to confirmation of the 

Debtor’s Second Amended Chapter 13 (the “Plan”) [D.E. 48] and in support thereof states as 

follows:

1. On January 3, 2022, Lorenzo Andrew Allen (the “Debtor”) filed a voluntary 

petition for relief under Chapter 13 of Title 11 of the United States Code (the “Bankruptcy Code”).

2. On March 28, 2022, the IRS filed proof of claim 3-1 (the “Claim”) setting forth an 

unsecured priority claim in the amount of $4,674.78 and unsecured general claim in the amount of 

$12,734.04.

3. On May 19, 2022, the Debtor filed the Second Amended Plan. [D.E. 48]

4. Section 1322(a)(2) of the Bankruptcy Code states that a plan “shall provide for the 

full payment, in deferred cash payments, of all claims entitled to priority under section 507 of this 

title, unless the holder of a particular claim agrees to a different treatment of such claim.” 11 

U.S.C. § 1322(a)(2). The IRS’ claim is entitled to priority treatment pursuant to 11 U.S.C. §

507(a)(8). 

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5. The IRS contends that the Debtor’s Plan fails to provide for any payments toward 

the IRS’ priority claim. Further, the Plan fails to provide for the payment of interest on the Claim 

as required by 11 U.S.C. § 511. 

6. Further, the IRS has no record of the Debtor filing a tax return for tax year 2020 

and 2021. Pursuant to 11 U.S.C. § 1308, not later than the day before the date on which the 341 

meeting was first scheduled, the Debtor is required to file all tax returns required to be filed in the 

4-year period preceding the petition date. 

7. Therefore, the Debtor’s Plan cannot be confirmed. 

WHEREFORE, the United States of America respectfully requests that the Court enter an

Order: (i) denying confirmation of the Debtor’s Plan; (ii) requiring the Debtor to file a plan that 

conforms to the Claim as required under the Bankruptcy Code; and (iii) providing for such further 

relief as this Court deems just and proper.

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

By: /s/Raychelle A. Tasher

RAYCHELLE A. TASHER

Assistant United States Attorney

Florida Bar No. 109291

Raychelle.Tasher@usdoj.gov

99 N.E. 4th Street, Suite 300

Miami, Florida 33132

Telephone: (786) 439-3185

Facsimile: (305) 530 -7139 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June 2, 2022, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 

served this day by transmission of Notices of Electronic Filing generated by CM/ECF to those 

parties registered to receive electronic notices of filing in this case or via U.S. mail as listed in the 

below Service List.

/s/Raychelle A. Tasher

RAYCHELLE A. TASHER

Service List

VIA CM/ECF Notice:

22-10014-SMG Notice will be electronically mailed to: 

Keith S Labell klabell@raslg.com, klabell@raslg.com

Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov

Christopher P Salamone csalamone@raslg.com, csalamone@raslg.com

Raychelle A. Tasher on behalf of Creditor United States of America, Department of 

Treasury/Internal Revenue Service ,

Raychelle.Tasher@usdoj.gov, Milton.Pacheco@usdoj.gov;Shannon.Patterson@usdoj.gov

Chad T Van Horn Chad@cvhlawgroup.com, 

chad@ecf.inforuptcy.com,g2320@notify.cincompass.com,chapter7@cvhlawgroup.com,broward

@cvhlawgroup.com,chapter11@cvhlawgroup.com,miami@cvhlawgroup.com

Robin R Weiner ecf@ch13weiner.com, ecf2@ch13weiner.com

VIA U.S. MAIL:

Synchrony Bank

PRA Receivables Management, LLC

PO Box 41021

Norfolk, VA 23541

/s/Raychelle A. Tasher

RAYCHELLE A. TASHER

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