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northern district of new york

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

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

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

In re Burnett

Ruling
Failure to include Social Security benefits in plan was not basis for denial of confirmation.
Procedural posture

Debtors filed separate petitions under chapter 13 of the Bankruptcy Code in two bankruptcy cases, and the same trustee was appointed to administer both cases. The trustee filed an objection to plans the trustees filed in both cases, claiming that the plans could not be confirmed because the debtors did not include social security payments they were receiving when they calculated their projected disposable income.

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Consumer opinion summary, case decided on January 21, 2011 , LexisNexis #0211-097

In re Cady

Ruling
Farm transferred to debtor through family estate planning was property of the estate so that debtor could cure default on secured loans entered into by father.
Procedural posture

In this chapter 12 case, a creditor moved for relief from the automatic stay "for cause" pursuant to 11 U.S.C.S. § 362(d)(1) with respect to certain real and personal property supporting the farming operation of the debtor.

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Consumer opinion summary, case decided on November 22, 2010 , LexisNexis #1210-086

In re Moore

Ruling
Modification of a secured claim on multi-use property not barred where mortgage covered both debtor's residence and other income producing property.
Procedural posture

Debtors, a husband and wife, filed a petition under chapter 13 and proposed a plan for repaying their creditors which bifurcated a secured claim that was filed by a mortgage servicing company. The mortgage servicing company filed an objection to the debtors' plan.

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Consumer opinion summary, case decided on November 18, 2010 , LexisNexis #1210-133

Muse v. Flagstar Bank (In re Muse)

Ruling
Scheduled prepetition mortgage not recorded until day before case was reopened could be avoided.
Procedural posture

In a adversary proceeding in a reopened chapter 7 bankruptcy case, the trustee filed a motion for summary judgment, endeavoring to avoid the mortgage lien of defendant bank. The mortgage had been listed in the debtor's bankruptcy schedules, but the mortgage, which was made several years before the debtor filed for bankruptcy, had not been recorded until the day the motion trustee's motion to reopen was granted.

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Consumer opinion summary, case decided on November 02, 2010 , LexisNexis #1210-089

In re King

Ruling
Debtor could not require creditor to repossess collateral rather than seek repayment.
Procedural posture

Debtors filed a petition under chapter 13, and a bank filed a claim against the debtors' bankruptcy estate, seeking repayment of loans it made that were guaranteed by the male debtor. The debtors sought an order under 11 U.S.C.S. § 502(b)(1) and Fed. R. Bankr. P. 3007(a) which disallowed part of the bank's claim.

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Consumer opinion summary, case decided on October 20, 2010 , LexisNexis #1210-011

Whites Lumber Inc. v. Barksdale (In re Barksdale)

Ruling
Builders did not owe fiduciary duty to lumber company that extended credit and resulting debt was dischargeable.
Procedural posture

Plaintiff lumber company filed separate adversary proceedings against defendant Chapter 7 debtors, a father and son, seeking a determination that the debtors owed the company debts that were nondischargeable under 11 U.S.C.S. § 523(a)(4). The debtors filed affirmative defenses and counterclaims seeking an award of attorney fees and costs, and the court consolidated the actions and tried both cases together.

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Commercial opinion summary, case decided on September 29, 2010 , LexisNexis #1110-051

In re Pagan

Ruling
Confirmation denied due to debtor's improper deduction of employer's contribution to health insurance plan.
Procedural posture

The Chapter 13 trustee objected to confirmation of the proposed plan by the debtor. At issue was whether was whether she was committing all of her projected disposable income to make payments to unsecured creditors under the plan as required by 11 U.S.C.S. § 1325(b)(1)(B) when she included her employer's portion of her health insurance premium as a living expense deduction but did not correspondingly reflect that premium payment as income.

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Consumer opinion summary, case decided on September 24, 2010 , LexisNexis #1010-130