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§ 1325(a)(3)

In re Amos

Ruling
Confirmation of plan including no payments to unsecured creditors while making payments on vacation home loan denied for lack of good faith.
Procedural posture

Chapter 13 debtors sought confirmation of a plan under that proposed to cure the arrearage on a mortgage loan secured by a vacation home, while also maintaining substantial monthly payments on only the first mortgage on that property. The plan proposed to make no payments to unsecured creditors, and the second mortgage creditor objected to the plan as not brought in good faith under 11 U.S.C.S. § 1325(a)(3).

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Consumer opinion summary, case decided on June 28, 2011 , LexisNexis #0811-067

In re Hicks

Ruling
Case dismissed where nonconfirmable plan was not proposed in good faith.
Procedural posture

Chapter 13 trustee objected to confirmation of debtors' plan and filed a motion to dismiss the debtors' bankruptcy case. At the end of the confirmation hearing, the debtors' counsel informed the court that, if the trustee's motion was granted, the debtors intended to appeal. Counsel made an oral motion on the record for the court to stay its order pending appeal.

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Consumer opinion summary, case decided on June 15, 2011 , LexisNexis #0711-136

In re Herrmann

Ruling
Confirmation of plan proposing retention of social security income and use of spouse's income to pay expenses denied due to lack of good faith.
Procedural posture

Chapter 13 debtors, a husband and wife, sought confirmation of their plan. The chapter 13 trustee objected to confirmation, arguing that the plan had not been proposed in good faith as required by 11 U.S.C.S. § 1325(a)(3) and that the plan did not meet the applicable commitment period.

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Consumer opinion summary, case decided on February 09, 2011 , LexisNexis #0311-095

In re Burnett

Ruling
Failure to include Social Security benefits in plan was not basis for denial of confirmation.
Procedural posture

Debtors filed separate petitions under chapter 13 of the Bankruptcy Code in two bankruptcy cases, and the same trustee was appointed to administer both cases. The trustee filed an objection to plans the trustees filed in both cases, claiming that the plans could not be confirmed because the debtors did not include social security payments they were receiving when they calculated their projected disposable income.

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Consumer opinion summary, case decided on January 21, 2011 , LexisNexis #0211-097

In re Thomas

Ruling
Confirmation denied as not proposed in good faith due to insufficient contribution of net monthly income to unsecured creditors.
Procedural posture

Debtor filed a petition under chapter 13 of the Bankruptcy Code and proposed a plan for repaying his creditors that excluded Social Security income ("SSI") he was receiving from his projected disposable income ("PDI") and paid a zero dividend to his unsecured creditors. A trustee who was appointed to administer the debtor's bankruptcy plan filed an objection to the plan.

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Consumer opinion summary, case decided on December 29, 2010 , LexisNexis #0211-098

In re Hingiss

Ruling
Confirmation denied due to debtors' attempt to cramdown "910 vehicle" claim.
Procedural posture

A creditor objected to the debtors' proposed chapter 13 plan based on lack of good faith under 11 U.S.C.S. § 1325(a)(3) and on the doctrine of equitable tolling.

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Consumer opinion summary, case decided on December 02, 2010 , LexisNexis #0111-034

In re Lofty

Ruling
Confirmation denied for lack of good faith due to support for son and grandson of debtors who were not legal dependents.
Procedural posture

Before the court for confirmation was debtors' Chapter 13 plan of reorganization. The trustee objected to confirmation.

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Consumer opinion summary, case decided on September 30, 2010 , LexisNexis #1010-129

In re McDonald

Ruling
Confirmation denied for bad faith due to retention of high end home and vehicles with little recovery for unsecured creditors.
Procedural posture

Bankruptcy debtors proposed a Chapter 13 plan which provided for retention of the debtors' home and vehicles, payment of state sales taxes which were mistakenly not paid by one debtor's businesses, and little or no distribution to unsecured creditors. The bankruptcy trustee objected to confirmation of the debtors' plan on the ground that the plan was not proposed in good faith as required by 11 U.S.C.S. § 1325(a)(3).

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Consumer opinion summary, case decided on September 30, 2010 , LexisNexis #1010-128

Fink v. Thompson (In re Thompson)

Ruling
Plain language of code precludes objection to plan for bad faith based on exclusion of social security income.
Procedural posture

Appellant, the Chapter 13 Trustee for appellee debtors' bankruptcy estate, challenged an order of the U.S. Bankruptcy Court for the Western District of Missouri confirming debtors' Chapter 13 plan.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on September 16, 2010 , LexisNexis #1010-063

In re Westing

Ruling
Plan that would result in substantial surplus to debtors could not be confirmed as filed in bad faith.
Procedural posture

The Chapter 13 debtors presented their amended plan for confirmation, and the trustee and several creditors filed objections to the plan, asserting that it was not proposed in good faith, as required by 11 U.S.C.S. § 1325(a)(3).

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Consumer opinion summary, case decided on July 13, 2010 , LexisNexis #1010-064