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§ 707(b)(2)

In re Brandenburg

Ruling
Presumption of abuse arose after adjustment of disposable income calculation to eliminate improper deduction.
Procedural posture

The debtor filed for relief under chapter 7. The U.S. Trustee filed a motion to dismiss the debtor's case for abuse, based on the presumption of abuse arising under 11 U.S.C. § 707(b)(2) or alternatively under the totality of the circumstances under 11 U.S.C. § 707(b)(3).

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opinion summary, case decided on May 15, 2007 , LexisNexis #0707-046

In re Skvorecz

Ruling
Lack of deduction for 401(k) contributions or 401(k) loan repayment in form B22A did not require dismissal on presumption of abuse.
Procedural posture

The United States Trustee filed a motion to dismiss debtor's chapter 7 case under 11 U.S.C. § 707(b)(1) and (2), asserting that the calculations in debtor's bankruptcy form B22A (statement of current monthly income and means test calculation for use in chapter 7 only), raised the presumption of abuse stated in 11 U.S.C. § 707(b)(2), that the debtor had not rebutted that presumption by showing any special circumstances.

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opinion summary, case decided on May 08, 2007 , LexisNexis #0607-046

In re Delbecq

Ruling
Debtor's student loan payments constituted "special circumstances" rebutting presumption of abuse.
Procedural posture

Debtor represented on the face of Official Form B22A that the "presumption of abuse" had arisen in her case because, according to the means test, she had disposable income of approximately $306 per month. Based on that representation, the U.S. Trustee filed a Motion to Dismiss pursuant to 11 U.S.C. § 707(b).

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opinion summary, case decided on April 26, 2007 , LexisNexis #0607-048

In re Chamberlain

Ruling
Debtor entitled to standard IRS ownership expense deduction for motor vehicle owned free and clear.
Procedural posture

After debtor filed a chapter 13 plan, the trustee objected thereto on the ground that the plan did not devote all of debtor's projected disposable income to payments to unsecured creditors as required by 11 U.S.C. § 1325(b)(1)(A). At issue was the propriety of certain calculations affecting debtor's monthly vehicle expenses and the impact on that issue of the "means test" in 11 U.S.C. § 707(b)(2)(A)(ii)(I).

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opinion summary, case decided on April 26, 2007 , LexisNexis #0607-047

In re Haman

Ruling
Debtor's nondischargeable obligation as co-signor on student loan for son who was unable to pay was a special circumstance rebutting the presumption of abuse.
Procedural posture

The United States Trustee (trustee) moved to dismiss the chapter 7 case of debtor pursuant to 11 U.S.C. § 707(b)(2)(A) or alternatively, pursuant to 11 U.S.C. § 707(b)(3). Debtor opposed the motion to dismiss, conceding that the presumption of abuse has arose, but asserting that the statutory presumption has been rebutted by her demonstration of a special circumstance justifying an additional expense under 11 U.S.C. § 707(b)(2)(B).

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opinion summary, case decided on April 20, 2007 , LexisNexis #0807-085

In re Hoerlein

Ruling
Debtors could claim expense allowance for payments on secured debt, even though no payments were to be made, where they intended to surrender the collateral.
Procedural posture

The United States Trustee ("UST") filed a motion to dismiss the debtors'bankruptcy case, pursuant to 11 U.S.C. § 707(b)(2), as an abuse of the provisions of chapter 7.

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opinion summary, case decided on April 03, 2007 , LexisNexis #0507-010

In re Kogler

Ruling
Mortgage and car loan payments were appropriate Form B22A deductions regardless of intent to surrender.
Procedural posture

Before the court was the U.S. Trustee's motion to dismiss debtors'chapter 7 case.

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opinion summary, case decided on March 30, 2007 , LexisNexis #0707-047

In re Gaylon

Ruling
Deduction for payments due on home mortgage allowed regardless of intent to surrender residence.
Procedural posture

The United States Trustee ("UST") filed a motion, pursuant to 11 U.S.C. § 707(b)(1), (2), to dismiss a debtor's chapter 7 bankruptcy case based on the presumption of abuse.

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opinion summary, case decided on March 22, 2007 , LexisNexis #0507-043

In re Templeton

Ruling
Amount of debtors'nondischargeable student loan debt established "special circumstances" rebutting presumption of abuse.
Procedural posture

The U.S. Trustee ("UST") moved to dismiss debtors'chapter 7 petition on grounds that they failed to rebut the presumption of abuse arising under 11 U.S.C. § 707(b)(2) by demonstrating "special circumstances."

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opinion summary, case decided on March 08, 2007 , LexisNexis #0507-081

In re Ferando

Ruling
Fluctuating income from commissions did not create "special circumstances" sufficient to rebust presumption of abuse.
Procedural posture

The United States Trustee ("UST") moved to dismiss the debtor's chapter 7 case pursuant to 11 U.S.C. § 707(b)(2) on the grounds that the filing constituted a substantial abuse of the provisions of chapter 7.

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opinion summary, case decided on March 01, 2007 , LexisNexis #0407-042