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§ 541(b)(7)

Perkins, In re

Ruling
Plan proposing 401(k) contributions of 15% of debtors' salary while paying unsecured creditors less than 25% of their claims was confirmed absent rebuttal of the presumption of good faith. (Bankr. S.D. Tex.)
Issue(s)
Property of the Estate; Exclusions; ERISA, Deferred Compensation and Annuity Plans.

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Consumer opinion summary, case decided on April 06, 2023 , LexisNexis #0623-036

Penfound, In re--Penfound v. Ruskin

Ruling
Chapter 13 debtor could not use retirement contributions from years earlier as a basis forshielding voluntary post-petition contributions from unsecured creditors. (6th Cir.)
Issue(s)
Property of the Estate; Exclusions; ERISA, Deferred Compensation and Annuity Plans.

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:
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 10, 2021 , LexisNexis #0921-090

Lehman Bros., In re--Lehman Bros. v. Giddens

Ruling
Contributions to “top hat” deferred compensation plan were not excluded from debtor’s bankruptcy estate. (Bankr. S.D.N.Y.)
Issue(s)
Property of the Estate; Exclusions; ERISA, Deferred Compensation and Annuity Plans.

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Commercial opinion summary, case decided on June 15, 2020 , LexisNexis #0720-091

Garza, In re

Ruling
Debtors were allowed to exclude monthly contributions the husband made to his 401(k) planwhen they determined their disposable income. (Bankr. S.D. Tex.)
Issue(s)
Property of the Estate; Exclusions; ERISA, Deferred Compensation and Annuity Plans.

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Consumer opinion summary, case decided on August 15, 2017 , LexisNexis #0917-076

In re Cantu

Ruling
Debtor could make voluntary contributions to retirement account and deduct the payments from disposable income.
Issue(s)
Could debtor claim an exemption in payments to a retirement plan after completing payments in the same monthly amount towards a loan from the plan?

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Consumer opinion summary, case decided on July 14, 2016 , LexisNexis #0816-050

Parks v. Drummond (In re Drummond)

Ruling
Bankruptcy court properly sustained trustee's objection to confirmation based on improper deductions for voluntary postpetition 401(k) contributions.
Procedural posture

Above-median income debtors filed a petition under chapter 13 of the Bankruptcy Code and proposed a plan for repaying their creditors which calculated their disposable income by deducting voluntary postpetition contributions they made to their 401(k) plans from their monthly income. The U.S. Bankruptcy Court for the District of Montana sustained the bankruptcy trustee's objection to confirmation of the debtors' plan, and the debtors appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 06, 2012 , LexisNexis #0912-054

Korneff v. Downey Regl Med. Center-Hospital Inc. (In re Downey Regl Med. Center-Hospital Inc.)

Ruling
Funds in deferred compensation plan were part of debtor hospital's unrestricted assets and were property of the estate.
Procedural posture

Appellant former employee sought review of an order from the United States Bankruptcy Court for the Central District of California, approving a stipulation between debtor hospital and an insurer regarding turnover of more than $1.6 million that the hospital had deposited with the insurer pursuant to a deferred compensation plan.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on November 16, 2010 , LexisNexis #0111-056

In re Gibson

Ruling
Confirmation denied due to debtor's failure to provide form for issuance of wage deduction in event of default.
Procedural posture

The standing chapter 13 trustee objected to confirmation of debtors' amended plan based on three alleged obstacles: (1) the amended plan failed to provide that all of debtors' projected disposable income to be received during the applicable commitment period would be paid into the plan, (2) the amended plan was not filed in good faith, and (3) it was unclear whether, as proposed, the Trustee could administer the amended plan.

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Consumer opinion summary, case decided on August 31, 2009 , LexisNexis #1009-018

In re Leahy

Ruling
Contributions to retirement account which were less than 15% of income were excluded from the estate.
Procedural posture

Debtors, a husband and wife, filed a petition under chapter 7. The chapter 7 trustee filed an objection to the debtors'claim of exemptions, asserting that contributions the wife made to a retirement account within one year of the date the debtors filed their petition were assets of the estate under Vt. Stat. Ann. tit. 12, § 2470(16). The trustee sought an order requiring the wife to turn over that money.

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opinion summary, case decided on July 03, 2007 , LexisNexis #0807-044