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southern district of georgia

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 Graham Bros. Constr. Inc.

Ruling
Late filed proof of claim disallowed where creditor intentionally had sought to avoid jurisdiction of bankruptcy court.
Procedural posture

A claimant of Chapter 11 debtor filed a motion to allow a late claim.

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Commercial opinion summary, case decided on May 16, 2011 , LexisNexis #0811-135

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

Adams v. Volpitto (In re Volpitto)

Ruling
Debtor employer's failure to make discretionary contributions to profit sharing plan did not result in nondischargeable debt.
Procedural posture

Former employees brought an adversary proceeding against bankruptcy debtor seeking a determination that a debt to the employees for the debtor's failure to make employer contributions to a retirement plan was nondischargeable under 11 U.S.C.S. § 523(a)(4) based on the debtor's breach of fiduciary duty as the plan trustee.

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Consumer opinion summary, case decided on March 22, 2011 , LexisNexis #0711-015

In re Joest

Ruling
Above-median debtor could claim ownership costs for two vehicles.
Procedural posture

An above-median income debtor filed a petition under chapter 13 and proposed a plan for repaying her creditors. The chapter 13 trustee filed an objection to confirmation of the debtor's plan, pursuant to 11 U.S.C.S. § 1325(b)(1)(B), claiming that it was neither reasonable nor necessary for the debtor, who was single, to claim ownership costs for two vehicles under 11 U.S.C.S. § 1325(b)(3).

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Consumer opinion summary, case decided on March 17, 2011 , LexisNexis #0511-031

Arch Ins. Co. v. Spivey (In re Spivey)

Ruling
Involuntary petition was proper where debtor failed to make payment on 90 percent of total debt held by petitioning creditors.
Procedural posture

Creditors sought entry of an order for relief under chapter 7 against the involuntary debtor. The involuntary debtor denied there were grounds for relief under 11 U.S.C.S. § 303(h), moved that the petition be dismissed.

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Consumer opinion summary, case decided on December 17, 2010 , LexisNexis #0211-001

In re Young

Ruling
Wavier of fees denied to debtor who was below income requirement but was able to pay in installments.
Procedural posture

A debtor filed an application for waiver of the chapter 7 filing fee pursuant to 28 U.S.C.S. § 1930(f)(1). During a hearing, the chapter 7 trustee orally objected to the application on the basis of a $ 2,000 bank account balance that the debtor listed in her application and claimed as exempt on her Schedule C.

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Consumer opinion summary, case decided on December 10, 2010 , LexisNexis #0211-032