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§ 1325(b)

In re Uhlig

Ruling
Chapter 13 plan excluding cash surrender value of whole life insurance policy could be confirmed.
Issue(s)
Whether the cash surrender value increase of a whole life policy over the life of the plan should be considered disposable income to be paid as an additional dividend to creditors with unsecured claims.

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Consumer opinion summary, case decided on January 30, 2014 , LexisNexis #0214-104

In re Afko

Ruling
Confirmation denied due to failure to devote savings following repayment of 401(k) loan to plan.
Issue(s)
Was debtors' plan required to step-up plan payments to account for the repayment of a 401(k) loan during the life of the plan or could debtors use savings as a "cushion" in the plan for unexpected expenses.

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Consumer opinion summary, case decided on November 15, 2013 , LexisNexis #1213-067

In re Garrepy

Ruling
Payments on stripped off mortgage could not be deducted from projected disposable income calculation.
Issue(s)
Whether debtors could deduct payments for a stripped mortgage when calculating projected disposable income under 11 U.S.C.S. § 1325(b)(1)(B).

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Consumer opinion summary, case decided on November 06, 2013 , LexisNexis #1113-137

In re Hall

Ruling
Plan confirmed over trustee's objection as 401(k) payments were properly removed from projected disposable income calculation.
Issue(s)
Whether court should sustain trustee's objection to confirmation on the grounds that by continuing to make a voluntary 401(k) contribution each month, debtor was not applying all projected disposable income to make payments to unsecured creditors in violation of 11 U.S.C.S. § 1325(b)(1)(B).

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Consumer opinion summary, case decided on October 22, 2013 , LexisNexis #0214-031

DeHart v. Knorr (In re Knorr)

Ruling
Child care expense was improper but could be used for first year of plan.
Issue(s)
Could debtor claim child care expense to cover debtor's care for minor children at scout camps under proposed plan .

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Consumer opinion summary, case decided on October 08, 2013 , LexisNexis #1013-135

In re Canniff

Ruling
Social Security payments for benefit of debtors' child properly excluded from disposable income calculation.
Issue(s)
Whether chapter 13 debtors were required to include Social Security payments in the amount of $700 per month they received for the benefit of their oldest child when they calculated the amount of income they had which could be used to fund their bankruptcy plan.

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Consumer opinion summary, case decided on September 19, 2013 , LexisNexis #1013-028

Danielson v. Flores (In re Flores)

Ruling
Duration of plan must be at least as long as the applicable commitment period.
Issue(s)
May above median debtors propose a chapter 13 plan with a term of three years rather than the five year applicable commitment period.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 29, 2013 , LexisNexis #0913-133

In re Dye

Ruling
Confirmation denied due to failure to allocate sufficient funds to pay off unsecured debt.
Issue(s)
Whether the Social Security income of a debtor's non-filing spouse was to be included in the calculation of a chapter 13 debtor's projected disposable income.

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Consumer opinion summary, case decided on August 16, 2013 , LexisNexis #0913-066

In re Carlyle

Ruling
Payments on non-debtor husband's truck were not made for household expenses and could be deducted from income calculations.
Procedural posture

The chapter 13 trustee objected to the debtor's plan on the ground that the marital adjustments the debtor took on Lines 13 and 19 of her "Chapter 13 Statement of Current Monthly Income and Calculation of Commitment Period and Disposable Income" means-test form were inappropriate.

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Consumer opinion summary, case decided on July 17, 2013 , LexisNexis #0813-030

In re Kramer

Ruling
Chapter 13 debtor's deduction for payments on second mortgage to be treated as unsecured had to be excluded from projected disposable income calculation.
Procedural posture

A chapter 13 trustee objected to confirmation of the debtors' plan on the grounds that the plan failed to direct all available projected disposable income to payment of creditors and on the grounds that they understated their projected disposable income and consequently, the plan did not satisfy the best efforts test of 11 U.S.C.S. § 1325(b)(1)(B).

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Consumer opinion summary, case decided on July 12, 2013 , LexisNexis #0813-068