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§ 1325(b)(1)

In re Paliev

Ruling
Confirmation denied due to failure to meet disposable income test.
Procedural posture

Chapter 13 trustee objected to confirmation of the debtor's amended chapter 13 plan on the grounds of lack of good faith under 11 U.S.C.S. § 1325(a)(3) and failure to meet the disposable income test under § 1325(b)(1)(B). The trustee also moved to dismiss the bankruptcy case on the grounds of lack of good faith and unreasonable delay that was prejudicial to creditors pursuant to 11 U.S.C.S. § 1307(c)(1).

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Consumer opinion summary, case decided on August 17, 2012 , LexisNexis #0912-100

In re Alexander

Ruling
Confirmation denied due to improper vehicle ownership expense and lack of good faith.
Procedural posture

Within days before filing their bankruptcy petition, bankruptcy debtors obtained a relatively small loan secured by the debtors' vehicle, and the debtors claimed a vehicle expense deduction based on the loan which reduced their disposable income to zero. The bankruptcy trustee moved to deny confirmation of the debtors' plan which proposed to pay nothing to unsecured creditors.

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Consumer opinion summary, case decided on August 01, 2012 , LexisNexis #0812-097

In re Murchek

Ruling
Plan confirmation denied due to failure to include future tax refunds as projected disposable income.
Procedural posture

Chapter 13 trustee objected to debtor's chapter 13 plan.

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Consumer opinion summary, case decided on July 17, 2012 , LexisNexis #0812-033

In re Reedy

Ruling
Confirmation denied due to excessive transportation deduction, resulting in payment of less than all projected disposable income to unsecured creditors.
Procedural posture

This matter came before the court for a telephonic hearing on confirmation of debtor's chapter 13 plan and the standing chapter 13 trustee's objection.

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Consumer opinion summary, case decided on June 26, 2012 , LexisNexis #0712-095

In re Konowicz

Ruling
Confirmation denied due to excessive living expenses and insufficient distribution to general unsecured creditors.
Procedural posture

This matter came before the court on a confirmation hearing filed by debtor with respect to debtor's proposed chapter 13 Plan. A creditor filed an Objection to Confirmation.

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Consumer opinion summary, case decided on May 17, 2012 , LexisNexis #0612-105

In re Hernandez

Ruling
Plan commitment period is to be established based on facts existing on the date of confirmation.
Procedural posture

The chapter 13 trustee objected to confirmation of an amended plan proposed by a chapter 13 debtor, challenging both the date on which debtor proposed to determine the applicable commitment period and the extent to which post-petition and pre-confirmation changes in household size affected that calculation. At issue was the import, on these issues, of 11 U.S.C.S. § 1325.

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Consumer opinion summary, case decided on March 23, 2012 , LexisNexis #0412-102

In re Pracht

Ruling
Plan proposing to pay separately classified unsecured student loan creditor more than general unsecured creditors did not unfairly discriminate.
Procedural posture

Debtor's chapter 13 plan was before the court for consideration of confirmation. The chapter 13 trustee objected to confirmation.

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Consumer opinion summary, case decided on January 10, 2012 , LexisNexis #0212-032

In re Grier

Ruling
Trustee's objection to confirmation based on debtor's failure to execute acknowledgement for turnover of possible future tax refunds overruled.
Procedural posture

Bankruptcy debtors proposed plans of reorganization but did not execute acknowledgments required by the bankruptcy court that tax refunds, economic stimulus tax rebates, employment bonuses, or any other payments received during the term of the plan would be turned over to the bankruptcy trustee as potential disposable income. The trustee objected to confirmation of the debtors' plans.

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Consumer opinion summary, case decided on September 15, 2011 , LexisNexis #1011-061

In re Dittrich

Ruling
Confirmation denied as debtor was not entitled as a matter of right to motor vehicle expense deduction based on IRS standards.
Procedural posture

A bankruptcy debtor proposed a plan which provided for payment to unsecured creditors from disposable income which the debtor calculated by including an additional expense deduction based on the age and mileage of the debtor's unencumbered vehicle. The bankruptcy trustee objected to confirmation of the debtor's plan.

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Consumer opinion summary, case decided on August 08, 2011 , LexisNexis #0911-027

In re Duarte

Ruling
Married debtors ordered to include tax refunds in projected disposable income calculation pursuant to separate filings rule.
Procedural posture

Debtor filed a petition under Chapter 13 of the Bankruptcy Code, and a trustee was appointed to administer the debtor's bankruptcy plan. The trustee filed an objection to confirmation of a plan the debtor proposed, claiming that the plan could not be confirmed under 11 U.S.C.S. § 1325(b)(1) because it did not require the debtor to contribute all his disposable income to the plan.

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Consumer opinion summary, case decided on July 12, 2011 , LexisNexis #0811-132