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§ 553

In re Spirakis

Ruling
Claim for which elements required for setoff could not be satisfied was not secured.
Issue(s)
Should debtor’s objection to secured portion of creditor’s claim be sustained?

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Consumer opinion summary, case decided on June 23, 2016 , LexisNexis #0716-080

Rofeh v. Massaji (In re Massaji)

Ruling
Judgment debt owed by creditor to debtor could be set off against debtor’s debt to creditor.(Bankr. C.D. Cal.)
Issue(s)
Could creditor’s judgment debt owed to debtor be set off against creditor’s claim against debtor?

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Consumer opinion summary, case decided on March 21, 2016 , LexisNexis #1016-124

In re Schmalenberg

Ruling
Debtors' postconfirmation claims for setoff were barred by res judicata.
Issue(s)
Could debtors claim a setoff on creditor's claim after plan confirmation?

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Consumer opinion summary, case decided on September 17, 2015 , LexisNexis #1015-055

Gladys Ragsdale Trust v. Tostige (In re Tostige)

Ruling
Trust's right of setoff against debtor beneficiary's future distributions survived discharge.
Issue(s)
Did trust have a right of recoupment and/or setoff against any debt it owed to debtor of debtor's debt to the trust, which would survive discharge?

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Consumer opinion summary, case decided on September 15, 2015 , LexisNexis #1015-056

Ahmad v. United States SSA (In re Ahmad)

Ruling
Prepetition setoff of Social Security retirement benefits was not avoidable.
Issue(s)
Could debtor recover retirement benefits withheld by the Social Security Administration due to overpayment?

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Consumer opinion summary, case decided on August 24, 2015 , LexisNexis #0915-060

Thelen LLP v. Fontana (In re Thelen LLP)

Ruling
Trustee's recovery of partner's draw payments in excess of income subject to offset of excess capital contribution.
Issue(s)
Was trustee entitled to recover draw payments received in excess of income by debtor law firm's partner and was partner entitled to an offset for excess contributions?

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Commercial opinion summary, case decided on August 21, 2015 , LexisNexis #0915-061

Louisiana Office of Cmty. Dev. v. Celebrity Contrs. Inc. (In re Celebrity Contrs. Inc.)

Ruling
Debtor corporation's claim against state as third party beneficiary could not be set off against state's own claim.
Issue(s)
Should debtor contractor's third party beneficiary claim against state for work elevating homes located in flood plain by offset by state's claim for recovery of payment for work contractor never performed?

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Commercial opinion summary, case decided on November 25, 2014 , LexisNexis #1214-132

Angell v. Mansour (In re Britt Motorsports LLC)

Ruling
Jury trial of avoidance proceeding denied due to transferees' assertion of setoff defense.
Issue(s)
Did creditors have the right to a jury trial of trustee's avoidance proceeding?

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Commercial opinion summary, case decided on October 22, 2014 , LexisNexis #1114-098

Angell v. Larabee (In re Tanglewood Farms Inc.)

Ruling
Transfers were not avoidable due where transferee was entitled to an offset against larger amount owed by debtor.
Issue(s)
Were allegedly preferential transfers by debtor to soybean grower avoidable or were the payments covered by the ordinary course of business exception?

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Commercial opinion summary, case decided on May 23, 2014 , LexisNexis #0614-098

In re Reed

Ruling
Relief from stay granted to allow setoff of postpetition tax refund against tax liability.
Issue(s)
Could IRS setoff postpetition tax refund against its priority tax claim .

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Consumer opinion summary, case decided on October 29, 2013 , LexisNexis #1113-091