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In re Snyder

Ruling
Confirmation denied as debtor could not surrender one parcel of real property and cram down claim secured by others.
Procedural posture

This matter came before the court for an evidentiary hearing on the confirmation of debtors' amended chapter 13 plan, which drew a creditor's objection.

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Consumer opinion summary, case decided on April 02, 2012 , LexisNexis #0412-136

In re Gillikin

Ruling
Contract rate of interest rather than adjusted prime was proper for creditor's claim based on terms of promissory note.
Procedural posture

A bankruptcy debtor proposed a disclosure statement regarding the debtor's proposed plan which provided for interest on a creditor's over-secured claim based on the prime rate plus risk adjustments. The creditor objected to the disclosure statement and asserted that the creditor was entitled to the higher contract rate of interest set out in promissory notes.

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Consumer opinion summary, case decided on March 03, 2012 , LexisNexis #0312-119

In re Juliano

Ruling
Damages awarded for creditor's violation of stay by withdrawing installment payments from debtor's account.
Procedural posture

The chapter 13 debtors filed a motion for sanctions and attorneys' fees pursuant to 11 U.S.C.S. § 362(k) for a creditor's alleged willful violation of the automatic stay. The creditor was properly served with the motion. An order granting a motion on default was issued.

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Consumer opinion summary, case decided on March 02, 2012 , LexisNexis #0312-114

Onteroa Assocs. v. Village of Fleischmanns (In re Onteora Assocs.)

Ruling
Tax foreclosure in which village obtained title postpetition was not avoidable.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant village alleging that a pre-petition in rem tax foreclosure proceeding by the village against the debtor's property was avoidable as a fraudulent transfer under 11 U.S.C.S. § 548 based on the village providing less than reasonably equivalent value for the property. The debtor moved for summary judgment.

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Commercial opinion summary, case decided on August 11, 2011 , LexisNexis #1111-052

In re Summer

Ruling
Dismissal for abuse denied where totality of circumstances showed inability to repay debt.
Procedural posture

The United States Trustee (UST) filed a motion to dismiss the Chapter 7 debtors' case for abuse pursuant to 11 U.S.C.S. § 707(b).

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Consumer opinion summary, case decided on June 10, 2011 , LexisNexis #0811-058

Coleman v. American Concrete Inc. (In re Sportsmans Link Inc.)

Ruling
Transfers could not be avoided where balance sheet and schedules showed debtor was solvent on petition date.
Procedural posture

Plaintiff, the Chapter 7 trustee, sought recovery of various pre-petition transfers made by the debtor to defendant transferees, alleging that they were either preferential or fraudulent under 11 U.S.C.S. §§ 547 and 548. The threshold issue was whether the debtor was insolvent at the time of the transfers, or became insolvent as a result of any of the transfers.

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Commercial opinion summary, case decided on May 24, 2011 , LexisNexis #0811-056

In re Eaton

Ruling
Above-median debtors' 47-month plan rejected as 60-month period was required.
Procedural posture

Debtors filed a joint petition under Chapter 13 of the Bankruptcy Code and proposed a plan for repaying their creditors that required them to make payments of $500 per month to the Chapter 13 trustee for 47 months and paid their unsecured creditors one percent of what they were owed. The Chapter 13 trustee filed an objection under 11 U.S.C.S. § 1325(b)(1)(B) to confirmation of the debtors' plan.

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Consumer opinion summary, case decided on April 05, 2011 , LexisNexis #0511-134

Community West Bank v. HSD Partners LLC (In re HSD Partners LLC)

Ruling
Creditor not entitled to relief from stay to proceed against property that was necessary to debtor's reorganization.
Procedural posture

In debtor's chapter 11 case, creditor filed a motion for relief from the automatic stay under 11 U.S.C.S. § 362, after preliminary hearings were conducted, a trial of all issues was held.

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Commercial opinion summary, case decided on April 01, 2011 , LexisNexis #0611-005

In re Eaton

Ruling
Confirmation of above-median debtors' plan denied due to failure to commit to five-year term.
Procedural posture

Debtors proposed a chapter 13 plan which provided for payments for slightly less than four years with a minimal distribution to unsecured creditors. The bankruptcy trustee objected to confirmation of the debtors' plan on the ground that the applicable commitment period for the debtors' plan under 11 U.S.C.S. § 1325(b) was five years.

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Consumer opinion summary, case decided on March 31, 2011 , LexisNexis #0611-031

AgSouth Farm Credit v. Del-A-Rae Inc. (In re Del-A-Rae Inc.)

Ruling
Relief from stay granted where debtor lacked equity in property despite potential cushion in event of market rebound.
Procedural posture

A creditor holding a lien on certain real estate belonging to a chapter 11 debtor, sought relief from stay per 11 U.S.C.S. § 362 as to that property on claims that debtor lacked any equity therein and that it was not necessary to an effective reorganization. Debtor challenged the valuation assigned by movant and sought to retain the property.

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Commercial opinion summary, case decided on March 29, 2011 , LexisNexis #0611-006