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§ 1325(a)(4)

In re Evans

Ruling
Till rate if interest was appropriate for debtors to unsecured creditors in chapter 13 plan.
Procedural posture

A hearing was held regarding confirmation of a debtor's proposed chapter 13 plan of reorganization. The debtor proposed to pay his unsecured creditors 100 percent of their allowed claims in monthly payments spread over a period of 36 consecutive months. The unresolved issue was the interest rate that had to be provided for the unsecured creditors in order for the plan to comply with the best-interest-of-creditors test in 11 U.S.C.S. § 1325(a)(4).

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Consumer opinion summary, case decided on July 28, 2010 , LexisNexis #0910-101

In re Anderson

Ruling
Objection to confirmation based on debtor's failure to schedule and pursue malpractice claim overruled.
Procedural posture

A creditor with a construction lien and judgment against the debtors objected to confirmation of their amended chapter 13 plan on the grounds that their failure to schedule and pursue a malpractice claim against their former attorney violated the best interest of creditors test of 11 U.S.C.S. § 1325(a)(4) and demonstrated the debtors' lack of good faith.

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Consumer opinion summary, case decided on June 03, 2010 , LexisNexis #0810-065

In re LaLonde

Ruling
Confirmation of plan in converted case denied due to insufficient payments to creditors.
Procedural posture

Debtor filed a chapter 7 petition, and when faced with the trustee's action to pursue preference recovery from her daughter and son-in-law, converted to chapter 13. The chapter 13 and chapter 7 trustees each objected to confirmation of the plan she proposed, and the chapter 7 trustee objected to certain claimed exemptions.

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Consumer opinion summary, case decided on May 07, 2010 , LexisNexis #0810-064

In re Lucio

Ruling
Confirmation denied where plan did not meet the best interests of creditors test.
Procedural posture

Debtors filed a petition under chapter 13 and a plan for repaying their creditors. A trustee who was appointed to administer the debtors' bankruptcy estate filed an objection to the debtors' plan, claiming that it did not meet the best interest of creditors test required by 11 U.S.C.S. § 1325(a)(4).

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Consumer opinion summary, case decided on February 08, 2010 , LexisNexis #0410-063

In re Gibson

Ruling
Plan modification denied for not providing for distribution equal to value of nonexempt property on original confirmation date.
Procedural posture

Debtors filed a petition under chapter 13 of the Bankruptcy Code and a plan for repaying their creditors. The court confirmed the debtors' plan on July 24, 2005, and in 2009, the debtors filed a modified plan. A chapter 13 trustee who was appointed to administer the debtor's bankruptcy estate filed a motion to dismiss the case, claiming that the debtors failed to comply with the terms of the confirmed plan.

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Consumer opinion summary, case decided on October 06, 2009 , LexisNexis #1009-138

In re Marcus

Ruling
Trustee's objection to plan on basis of improper homestead exemption overruled where debtor was in compliance with state statute.
Procedural posture

The debtor filed a chapter 13 petition and plan. The plan did not propose any payments to unsecured creditors. The chapter 13 trustee objected to confirmation of the plan.

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Consumer opinion summary, case decided on February 04, 2009 , LexisNexis #0309-133

In re Rascento

Ruling
Case dismissed due to failure of chapter 13 plan to provide for better recovery than in chapter 7 and debtor's failure to appear.
Procedural posture

The chapter 13 debtor objected to a claim filed by the bank that held the mortgage on his residence, contending that the bank could not prove that it was the true owner of the note and that the note had been paid in full. The bank moved for relief from the automatic stay. The bankruptcy trustee moved to dismiss the bankruptcy, asserting that the debtor's plan did not comply with 11 U.S.C.S. §§ 1322 and 1325.

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Consumer opinion summary, case decided on September 22, 2008 , LexisNexis #1208-026

In re Shepard

Ruling
Debtors' exemption in tax refund limited to originally projected amount, not later undisclosed excess.
Procedural posture

A chapter 7 trustee filed an objection to debtors' exemptions and amended exemptions pursuant to Fed. R. Bankr. P. 4003(b), alleging that the debtors knowingly made a false representation as to the amount of their income tax refunds. He sought an order requiring the debtors to turn over the amount of undisclosed tax refunds.

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Consumer opinion summary, case decided on August 25, 2008 , LexisNexis #1208-056

In re Baillargeon

Ruling
Plan did not meet "best interests of creditors" test due to omission of value of debtor's interest in house.
Procedural posture

Debtors filed a petition under chapter 13 of the Bankruptcy Code, and a plan for repaying their creditors. A trustee was appointed to represent the bankruptcy estate, and he filed an objection to the debtors' plan.

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Consumer opinion summary, case decided on June 13, 2008 , LexisNexis #0808-027

In re Foehrkalb

Ruling
Debtors'maintenance of three cars necessary to household did not violate best interests of creditors test.
Procedural posture

The chapter 13 trustee filed an objection to the debtors' proposed plan stating that the plan did not meet the "best interests" test of 11 U.S.C. § 1325(a)(4). The main focus of the trustee's objection was the debtors'proposed retention of a vehicle.

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Consumer opinion summary, case decided on November 13, 2007 , LexisNexis #1207-090