United States First Circuit

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Bates v. Citimortgage, Inc., 16-1228

In an action filed by plaintiffs who filed for Chapter 7 bankruptcy, in which their mortgage debt was discharged, and defendants foreclosed on their home, alleging that the IRS Form 1099-A plaintiffs' received in the mail alerting them that the foreclosure might have tax consequences were a coercive attempt to collect on the mortgage debt that had been discharged, the district court's judgment in favor of defendants is affirmed where the Forms were not objectively coercive attempts to collect a debt.

Appellate Information

  • Decided
  • Published 2016/12/14




  • United States First Circuit