I can tell you this. The IRS made a legitimate adjustment to my 2008 income taxes (I messed something up), so I ended up owing $2500 for 2008 and I filed in 2009. That tax was not paid when I filed. It is included in my chapter 13 plan. I got the notice of the adjustment about a month before I filed, so I don't have any interest or penalties assessed as of my filing date.
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