Christopher Justice sought a declaration in bankruptcy that federal tax debts for several years were dischargeable. The bankruptcy court concluded that his late-filed income-tax forms did not qualify as returns under the governing statute, and the district court affirmed. The Eleventh Circuit adopted the multi-factor test used by other federal courts for determining whether a document is a tax return, including whether it represents an honest and reasonable effort to satisfy the tax law. Although the statute’s filing-requirement language did not impose a categorical rule for every late filing, Justice’s forms were filed years after the deadlines and did not reflect the required good-faith effort. The court held that the forms therefore were not returns for purposes of dischargeability. The resulting tax obligations were debts for which no return had been filed and were not dischargeable in bankruptcy. The court affirmed the district court’s judgment while declining to adopt a per se rule that every delinquent filing is disqualified.