As cases attempting to stretch the reach of the FDCPA continue, courts continue to hold steady, requiring a voluntary credit transaction. The Middle District of North Carolina joined the fray last week, holding that unpaid property taxes are not a debt under the FDCPA. Armstrong v. Bardill, C.A. No. 1:13-cv-1140 (M.D.N.C. Sep. 2, 2014). In dismissing the complaint, the court noted that a threshold requirement for application of the FDCPA is an attempt to collect a debt. The court held that property taxes and associated costs do not arise out of the type of “transaction” contemplated by the FDCPA.