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Lyons v. Sandifur (In re Metropolitan Mortg. & Secs. Co.)

Ruling
Trustee of trust dismissed due to receipt of unlawful dividend payments.
Procedural posture

Plaintiff, the plan administrator and trustee of the creditors' trust, the successor-in-interest to the debtor, filed an adversary proceeding asserting a claim for avoidance and recovery of avoidable transfers under 11 U.S.C.S. § 548 and recovery of unlawful dividend payments under Wash. Rev. Code § 23B.06.400 and 11 U.S.C.S. § 108. Defendant, both the trustee of a trust and a shareholder and director of the debtor, moved to dismiss the claims.

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Commercial opinion summary, case decided on April 11, 2008 , LexisNexis #0608-101

In re Magwood

Ruling
Seller's right to reclaim vehicle was stayed on petition date.
Procedural posture

Creditor filed a motion for relief from the automatic stay to exercise its right under 11 U.S.C.S. § 546(c)(1) to reclaim a vehicle sold to the debtor. The debtor objected to the motion. The issue was whether a sale must have been in the ordinary course of business of both the buyer and seller to give the seller a right of reclamation.

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Consumer opinion summary, case decided on February 22, 2008 , LexisNexis #0308-122

Branigan v. Bateman (In re Bateman)

Ruling
Debtor could file second chapter 13 case more than two years after first filing even though not eligible for discharge.
Procedural posture

In a consolidated appeal, appellant chapter 13 trustee appealed the order of the District Court for the District of Maryland affirming both the bankruptcy court's denial of his motion to dismiss the chapter 13 petition of a single debtor and its confirmation of his chapter 13 plan and the bankruptcy court's orders denying his motion to dismiss the chapter 13 petition of joint debtors and likewise confirming their chapter 13 plan.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on February 04, 2008 , LexisNexis #0208-128

In re Strickland

Ruling
Vehicle expense dedcution from projected disposable income calculation limited to current acutal costs as of petition date.
Procedural posture

Creditor filed an objection to confirmation of the debtors' proposed chapter 13 plan contending that the debtors had not devoted all of their disposable income to unsecured creditors for the required period. The issue was whether the debtors, in determining their projected disposable income, could deduct the full Internal Revenue Service (IRS) Local Standard allowance for vehicle ownership when their actual costs were less than the allowance.

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Consumer opinion summary, case decided on January 24, 2008 , LexisNexis #0508-020

In re Bartolome

Ruling
Claim secured by mobile home that was not real property under state law was not protected from bifurcation.
Procedural posture

A creditor filed an objection to confirmation of debtor's chapter 13 plan.

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Consumer opinion summary, case decided on September 21, 2007 , LexisNexis #1007-124

In re Warren

Ruling
Debtor rebutted presumption of projected disposable income as calculated on Form 22C by demonstrating future reduction in income.
Procedural posture

A debtor filed for relief under chapter 13 and submitted a proposed plan. A chapter 13 trustee objected, claiming that the proposed plan did not satisfy the "projected disposable income test" of 11 U.S.C. § 1325(b)(1).

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Consumer opinion summary, case decided on September 06, 2007 , LexisNexis #1007-130

In re Baxter

Ruling
Proceeds of postconfirmation cause of action were disposable income warranting modification of plan.
Procedural posture

The movant, the chapter 13 trustee, sought to modify the confirmed plan in debtor's case. The trustee requested that the non-exempt, net proceeds due the debtors from their settlement of a lawsuit be paid under the plan for the benefit of unsecured creditors. The debtors objected to the motion.

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opinion summary, case decided on August 20, 2007 , LexisNexis #0907-124

In re Barrett

Ruling
Anti-bifurcation provision of hanging paragraph allowed debtors to surrender vehicle in full satisfaction of secured debt.
Procedural posture

Debtors filed a petition under chapter 13 and a plan for repaying their creditors. A creditor that held a purchase-money security interest in a vehicle the debtors owned filed an objection to confirmation of the debtors'plan.

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opinion summary, case decided on July 17, 2007 , LexisNexis #0907-015

In re Armstrong

Ruling
Above median debtors could claim deduction on Form B22C for truck owned free and clear of liens.
Procedural posture

After debtors filed an Official Bankr. Form B22C in their chapter 13 case reflecting a $471 expense deduction relating to a truck that they owned free and clear of liens, the trustee objected, contending that debtors were not entitled to the full amount of the "Local Standard" in the Internal Revenue Manual ("IRM") because debtors were not making payments on the truck. At issue was whether 11 U.S.C. § 707(b)(2)(A)(ii)(I) permitted that deduction.

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opinion summary, case decided on June 12, 2007 , LexisNexis #0707-079

In re Yelverton

Ruling
Secured creditor entitled to interest payments at Till rate.
Procedural posture

The debtors filed for relief under chapter 13 and submitted a proposed plan. The creditor objected to the plan, as amended, because the debtor proposed that the creditor receive the interest rate of 7.2% as provided for in the contract between one of the debtors and the creditor. The creditor sought interest at the prime rate of 8.25% plus a 1% adjustment.

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opinion summary, case decided on May 21, 2007 , LexisNexis #0707-013