October 18, 2017 Ninth Circuit Creates Split on Appellate Standard for ‘Consumer Debt’ Determination Dissenter contends that the majority misread the circuit’s own precedent. 9th Circuit , July 15, 2016 Circuit Split Widens on Test for Nondischargeability from Late-Filed Tax Returns Ninth Circuit avoids the one-day-late rule for nondischargeability of tax debts. 9th Circuit ,