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§ 105

In re Bost

Ruling
Attorney was ordered to disgorge all fees paid by debtors and was referred for professional discipline and criminal investigation since the attorney provided inadequate representation for all of the debtors.
Procedural posture

An attorney who represented numerous bankruptcy debtors repeatedly filed bankruptcy petitions and pleadings on behalf of debtors which contained errors and omissions, and the attorney was ordered to show cause why the attorney should not be sanctioned.

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opinion summary, case decided on April 26, 2006 , LexisNexis #0606-046

Whitaker v. Baxter (In re Whitaker)

Ruling
Court reinstated automatic stay for second filing based on its equitable powers to prevent abuse of process since debtors had acted in good faith and creditors had not objected to stay reinstatement.
Procedural posture

Debtors who filed a second chapter 13 petition within a one year period moved to reinstate the automatic stay of pursuant to 11 U.S.C. § 362(c)(3)(B) or (c)(4)(B) as amended following the effective date of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. The bankruptcy court considered whether such relief was available, or whether the application of 11 U.S.C. § 105(a) relief was warranted.

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opinion summary, case decided on April 20, 2006 , LexisNexis #0606-036

In re Meyers

Ruling
Debtor was granted motion for sanctions against creditor for violating discharge injunction by continuing to call debtor multiple times to attempt to collect.
Procedural posture

Movant Chapter 7 debtor sought monetary sanctions against respondent creditor for its alleged willful violation of a discharge injunction. The bankruptcy court held a hearing on the motion.

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opinion summary, case decided on April 06, 2006 , LexisNexis #0506-005

Wells Fargo Bank of Texas N.A. v. Sommers (In re Amco Ins.)

Ruling
Bankruptcy court erred in applying substantive consolidation nunc pro tunc since the court had authorized pursuit of state court litigation that it later invalidated well after the litigation had ended in a settlement.
Procedural posture

Appellant creditor appealed to the District Court for the Southern District of Texas, the bankruptcy court's order granting substantive consolidation. The district court ruled unfavorably to the creditor and the creditor appealed. The significance of the case related to the nunc pro tunc substantive consolidation of the assets and liabilities of a corporation in bankruptcy and its sole shareholder, not in bankruptcy (until afterwards).

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on March 31, 2006 , LexisNexis #0406-081

In re Uzialko

Ruling
Debtor's motion to compel IRS to consider debtor's offer-in-compromise rather than proceed under plan confirmation process was denied.
Procedural posture

Movant chapter 13 debtors filed a motion to compel respondent United States, on behalf of its agency, the IRS to consider an offer-in-compromise submitted by the debtors during the pendency of their bankruptcy case. The court held a hearing on the motion

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opinion summary, case decided on March 29, 2006 , LexisNexis #0606-079

Intl Enter. v. Classic Asset Liquidation Mgmt. LLC (In re Eddy)

Ruling
Debtor was denied a discharge due to default, and the debtor was given a deadline to comply with a prior court order or face civil contempt sanctions.
Procedural posture

Pending was a motion of plaintiff interested party for entry of default judgment pursuant to the court's order of September 23, 2005 filed in its adversary proceeding against defendant debtor. Also under consideration was the motion of plaintiff chapter 7 trustee for civil contempt and sanctions, filed in debtor's underlying bankruptcy case, but seeking sanctions against debtor, including entry of a default judgment in an adversary proceeding.

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opinion summary, case decided on March 16, 2006 , LexisNexis #0406-008

In re Indus. Commer. Elec. Inc.

Ruling
Court denied a motion to approve a settlement since the movants'proposed order required the dismissal of an action filed by the IRS in another court.
Procedural posture

Movants, the debtors, a bank, and the official committee of unsecured creditors, sought entry of an order pursuant to 11 U.S.C. § 105(a), for approval of a settlement reached between the three moving parties. The IRS objected to the motion on several grounds, including the fact that the settlement would preclude the IRS from proceeding against the bank in a related district court proceeding.

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opinion summary, case decided on February 14, 2006 , LexisNexis #0306-077

In re Epley

Ruling
Debtor was denied motion to convert case to chapter 13 since debtor had insufficient income to propose a confirmable plan and, thus, the motion was filed in bad faith.
Procedural posture

The debtor moved to convert her chapter 7 case to one under chapter 13 as well as on the motion of the chapter 7 trustee to sell property of the estate. The chapter 7 trustee objected to conversion.

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opinion summary, case decided on December 28, 2005 , LexisNexis #0506-006

Simantob v. Lahijani (In re Lahijani)

Ruling
Motion for substantive consolidation was granted where the debtor controlled and acted as the alter ego of two non-debtor corporations.
Procedural posture

Plaintiff creditors brought an adversary proceeding against defendant bankruptcy debtor to determine, inter alia, the dischargeability of debts. The creditors moved for substantive consolidation of two non-debtor corporations with the debtor on the ground that the debtor controlled and acted as alter ego of the corporations.

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opinion summary, case decided on October 03, 2005 , LexisNexis #0106-071