Bunyan

Debtors-Appellants Bruce and Ruth Bunyan and Verla McCullum 1 (collectively “Debtors-Appellants”), appeal the district court’s affirmance of the order of the bankruptcy court, which overruled their objections to claims for income taxes filed by the Internal Revenue Service in their respective Chapter 13 proceedings. The Debtors-Appellants argue that the bankruptcy court erred in finding that the Bankruptcy Code and res judicata barred them from challenging the validity of the income tax assessments in their bankruptcy proceedings. We have jurisdiction under 28 U.S.C. §§ 158 (d) and 1291. We affirm the bankruptcy court’s decision to overrule the Debtors-Appellants’ objections, because we conclude that it lacked jurisdiction to consider the validity of the tax assessments.

When reviewing an appeal from a bankruptcy court, “[w]e independently review the bankruptcy court’s decision and do not give deference to the district court’s determinations.” In re Saxman, 325 F.3d 1168, 1172 (9th Cir.2003). The bankruptcy court’s conclusions of law and interpretation of the Bankruptcy Code are reviewed de novo. See In re BCE West, L.P., 319 F.3d 1166, 1170 .

There are two sets of…