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southern district of mississippi

In re Walls

Ruling
Issue of whether IRS secured nonpriority claim was discharged in prior case has to be resolved in an adversary proceeding as it went to eligibility.
Issue(s)
Whether a chapter 13 debtor's claim that an unsecured nonpriority claim the Internal Revenue Service ("IRS") filed against his bankruptcy estate could be resolved as a contested matter or had to be resolved in an adversary proceeding, and if an adversary proceeding was required, whether that proceeding had to be filed in the debtor's earlier bankruptcy case after that case were reopened or could be filed in the debtor's open chapter 13 case.

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Consumer opinion summary, case decided on July 09, 2013 , LexisNexis #0813-001

Wolgin v. Pilger (In re Pilger)

Ruling
Debt was dischargeable absent evidence that representation by debtor's agent was false when made.
Procedural posture

Creditors, real estate investors (the investors), filed a complaint asserting that defendant debtor's alleged obligations to the investors should be excepted from discharge under 11 U.S.C.S. § 523(a)(2)(A).

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Consumer opinion summary, case decided on May 28, 2013 , LexisNexis #0613-087

In re Taylor

Ruling
Notice of payment change was not entitled to prima facie presumption of validity and disallowed where creditor did not meet necessary burden.
Procedural posture

Before the court was debtor's objection to proof of claim (the "Objection"), and the creditor's response thereto. Also before the court was the creditor's Notice of Mortgage Payment Change (the "First Payment Change") and debtor's objection thereto, as well as the creditor's Notice of Mortgage Payment Change (the "Second Payment Change"), and debtor's objection thereto. A hearing was held.

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Consumer opinion summary, case decided on March 27, 2013 , LexisNexis #0413-105

Lentz v. Myers (In re Myers)

Ruling
All property held by debtor as of date of bad faith conversion to chapter 7 was property of the estate.
Procedural posture

The chapter 7 trustee sought an adjudication that certain legal causes of action pursued by defendants, debtors and their subsequently-formed corporation against third-parties in a district court action were property of the debtors' chapter 7 bankruptcy estate, and whether the corporation was a successor in interest to the debtors.

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Consumer opinion summary, case decided on February 14, 2013 , LexisNexis #0313-105

County Credit LLC v. Tillman (In re Tillman)

Ruling
Debtor spouse's failure to disclose outstanding payday loan to creditor resulted in nondischargeable debt.
Procedural posture

Creditor filed an adversary action against joint debtors alleging debts owed by each debtor were nondischargeable under 11 U.S.C.S. § 523(a)(2) because the debtors failed to disclose payday loans allegedly outstanding at the time each debtor obtained their respective loan from the creditor.

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Consumer opinion summary, case decided on November 30, 2012 , LexisNexis #1212-118

In re Superior Boat Works

Ruling
Plan could be confirmed where all members of a particular class casting ballots approved.
Procedural posture

This matter came before the court to consider the Amended Plan of Reorganization and the Report of Ballots and Request for Confirmation Pursuant to 11 U.S.C.S. § 1129(b)(1) (the Ballots Rep, t) submitted by debtor. No objection to the Plan was filed.

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Commercial opinion summary, case decided on November 21, 2012 , LexisNexis #1212-062

In re Superior Boat Works

Ruling
Corporation controlled by debtor's principals was not entitled to an administrative expense claim for attorneys' fees.
Procedural posture

A related corporation controlled by the same principals as the debtor filed a motion for determination that its payments to two attorneys for pre-petition fees and costs constituted priority administrative expenses and were reimbursable. No objection to the motion was filed.

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Commercial opinion summary, case decided on November 21, 2012 , LexisNexis #1212-044

In re Prevalence Health LLC

Ruling
Transfer to debtor's president and chief operating officer avoided as preferential given inability to establish ordinary course of business exception.
Procedural posture

The chapter 11 trustee filed an action against defendant the president and chief operating officer of the debtor, to set aside a payment as a preference pursuant to 11 U.S.C.S. § 547. Defendant argued that the transfer was not a preference because it was made in the ordinary course of the debtor's business under § 547(c)(2). Both parties filed motions for summary judgment.

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Commercial opinion summary, case decided on November 07, 2012 , LexisNexis #1212-024

In re Cooper

Ruling
Confirmation denied as student loan debt was treated unfairly.
Procedural posture

A below-median income debtor who was not eligible to declare chapter 7 bankruptcy filed a petition under chapter 13 of the Bankruptcy Code and proposed a plan that did not pay anything to unsecured creditors. A hospital that was owed $24,760 filed an objection to confirmation of the debtor's plan but negotiated a settlement with the debtor, and the debtor asked the court to approve the settlement and to confirm her amended plan.

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Consumer opinion summary, case decided on August 31, 2012 , LexisNexis #0213-100

Johnson v. Magee Rentals Inc. (In re Johnson)

Ruling
Actual damages and damages for emotional distress, but not punitive damages, awarded due to creditor's violation of stay despite oral notice of bankruptcy.
Procedural posture

Plaintiff chapter 13 debtor filed a complaint against defendant creditor seeking damages for violation of the automatic stay pursuant to 11 U.S.C.S. § 362(k).

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Consumer opinion summary, case decided on August 28, 2012 , LexisNexis #0912-073