The 505 Project White Paper

The 505 Project White Paper is the cornerstone of our educational mission. It’s a living document that examines how 11 U.S.C. § 505 empowers bankruptcy courts to determine tax liabilities — a provision that has been largely overlooked by both bankruptcy and tax professionals.

This paper brings together decades of academic thought, practical experience, and collaborative research to help the legal community understand what’s possible when Section 505 is properly applied. It’s written for attorneys, accountants, bankers, and policy thinkers who see the value in expanding the conversation and building precedent that benefits debtors, creditors, and the broader financial system.

Why This Paper Exists

  • To educate the professional community about the scope and authority granted by Section 505
  • To connect practitioners across law, accounting, and finance who can test and refine its real-world use.
  • To document early findings, case interpretations, and procedural insights that can serve as a foundation for future case law.
  • To protect and preserve the intellectual framework being developed by the nonprofit organization Title Eleven in 2025 and Beyond.

    A Practical Guide to Section 505

    The White Paper is divided into focused sections designed to help different audiences interpret and apply Section 505 effectively

  • For Bankruptcy Attorneys

    Understand how to identify eligible cases, structure pleadings, and present arguments that allow the court to determine tax liabilities within the bankruptcy itself.

  • For Tax Attorneys and CPAs

    Learn how to collaborate with bankruptcy counsel, apply § 505 to protect clients from prolonged IRS disputes, and reduce the timeline for resolving tax debt.

  • For Financial Institutions

    Discover how banks and special-assets teams can leverage this strategy to protect collateral and recover troubled government-backed loans more efficiently.

  • For Educators and Policy Professionals

    Review the policy implications of integrating tax determination into bankruptcy practice, and explore the potential ripple effects on financial stability and judicial efficiency.

Access the Full Document

The complete White Paper is available as a downloadable PDF. Updates are released as new interpretations, research, and case developments emerge.

Download the White Paper (PDF)

Contribute to the Research

The 505 Project welcomes collaboration from professionals who can bring practical experience, academic insight, or case data to strengthen this work. Your contributions help ensure the accuracy, depth, and relevance of this initiative.

Get Involved