NOTES 655 Tax Lawyer, Vol. 55, No. 2 NOTE DRUNK AND ORDERLY: THE ANOMALOUS HOLDING OF IN RE FRETZ AFFECTS BANKRUPT TAXPAYERS In In re Fretz,1 the Eleventh Circuit further transformed its definition of what constitutes a willful evasion of tax, thus triggering the exception in 11 U.S.C. section 523(a)(1)(C) (“section 523”) which makes certain unpaid taxes nondischargeable in bankruptcy. In reaching its decision, the Eleventh Circuit held that a debtor’s intentional failure to file tax returns...