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§ 707(b)(2)(A)

In re Hays

Ruling
Plan confirmation denied due to debtors' inclusion of expenses for adult daughter and fiance in means test calculation.
Procedural posture

A trustee objected to confirmation of the debtors' chapter 13 plan.

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Consumer opinion summary, case decided on April 29, 2008 , LexisNexis #0608-016

In re Law

Ruling
Confirmation denied due to improper deductions on Form 22C including expenses for unencumbered vehicle.
Procedural posture

Debtor's chapter 13 matter was before the court on the trustee's objection to confirmation of plan.

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Consumer opinion summary, case decided on April 24, 2008 , LexisNexis #0508-085

In re King

Ruling
Debtor could not deduct court ordered payments in spouse's own bankruptcy from current monthly income.
Procedural posture

A debtor filed for relief under chapter 7 of the United States Bankruptcy Code. The U.S. trustee filed a motion to dismiss the chapter 7 case as abuse.

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Consumer opinion summary, case decided on April 18, 2008 , LexisNexis #0608-085

In re Anderson

Ruling
Debtor properly deducted both secured debt on collateral to be surrendered and authorized amound for leased vehicle in calculating projected disposable income.
Procedural posture

A creditor of chapter 13 debtors objected to the confirmation of their plan.

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Consumer opinion summary, case decided on March 21, 2008 , LexisNexis #0408-051

In re Roberts

Ruling
Debtor could take transportation ownership expense on vehicle owned free and clear.
Procedural posture

A bankruptcy debtor with above-median income proposed a chapter 13 plan which claimed a standard deduction from disposable income for transportation ownership expense. The trustee verbally objected to the deduction on the ground that the debtor had no vehicle loan or lease payment, and the debtor moved for a determination of the applicable transportation ownership expense.

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Consumer opinion summary, case decided on February 28, 2008 , LexisNexis #0408-014

In re Davis

Ruling
Debtor could claim deduction for operating expenses debtor was paying on vehicle debtor did not own.
Procedural posture

The debtor moved for confirmation of her proposed chapter 13 plan. The chapter 13 Trustee objected to confirmation, arguing that the debtor was not entitled to claim the ownership expense for a vehicle that she owned free and clear of liens and made no "ownership" payment on the vehicle. The trustee also asserted that the debtor was not entitled to claim the operating expense for two vehicles because the debtor only owned one vehicle.

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Consumer opinion summary, case decided on February 26, 2008 , LexisNexis #0308-123

Ransom v. MBNA Am. Bank (In re Ransom)

Ruling
Bankruptcy court properly held that above-median debtor could not claim vehicle ownership expense for vehicle owned free and clear.
Procedural posture

A debtor filed a petition under chapter 13 of the Bankruptcy Code and a plan for repaying his creditors. A bank filed an objection to confirmation of the debtor's plan, claiming that the debtor was not devoting all his projected disposable income to fund the plan, pursuant to 11 U.S.C. § 1325(b)(1)(B). The United States Bankruptcy Court for the District of Nevada denied confirmation, and the debtor appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on December 27, 2007 , LexisNexis #0208-082

Ransom v. MBNA America Bank (In re Ransom)

Ruling
Certification to 9th Circuit Court of Appeals on issue of whether debtor could not claim disposable income deduction for expenses on vehicles owned free and clear.
Procedural posture

The U.S. Bankruptcy Court for the District of Nevada denied confirmation of a chapter 13 plan filed by appellant debtor. The denial was based upon the fact that debtor sought to take deductions for vehicle ownership expenses as part of the calculation of his projected disposable income, when in fact he had no such expenses. A motions panel of the Bankruptcy Appellate Panel granted leave for debtor's appeal under 28 U.S.C. § 158(a)(3), (b).

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on December 27, 2007 , LexisNexis #0308015

In re Lindstrom

Ruling
Debtor could deduct payments on vehicle repossessed prior to petition date from disposable income calculation.
Procedural posture

The United States Trustee (UST) moved to dismiss the debtor's chapter 7 case pursuant to 11 U.S.C. § 707(b) on the grounds that the filing constituted a substantial abuse of the provisions of chapter 7. The issue was whether, under 11 U.S.C. § 707(b)(2)(A)(iii)(I), the debtor could deduct, as an allowable expense, monthly payments on a car loan when the car was repossessed prior to the filing of the UST's motion to dismiss.

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Consumer opinion summary, case decided on December 12, 2007 , LexisNexis #0308-016

In re Burmeister

Ruling
Debtors properly included "contractually due" mortgage payments on property intended for surrender in disposable income calculation.
Procedural posture

The debtors moved for confirmation of their proposed chapter 13 plan. The standing chapter 13 trustee objected, arguing that the debtors were not devoting all of their projected disposable income to the plan because their calculation of disposable income deducted mortgage payments that they had stopped making on a home that they intend to surrender. The trustee added that the amended plan therefore was not proposed in good faith.

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Consumer opinion summary, case decided on November 16, 2007 , LexisNexis #1207-083