Skip to main content

§ 707(b)(2)

In re McGhee

Ruling
Ransom reasoning applied to prohibit mortgage/rent deduction where debtor did not own the subject property or make mortgage payments.
Issue(s)
Could debtor claim a deduction for residence which she did not own or on which she did not pay the mortgage.

ABI Membership is required to access the full summary of In re McGhee Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on September 18, 2013 , LexisNexis #1013-023

In re Bradley

Ruling
Student loan debt could constitute "special circumstances" to rebut presumption of abuse.
Issue(s)
Could debtors cite student loan obligations as "special circumstances" in order to rebut the presumption of abuse.

ABI Membership is required to access the full summary of In re Bradley Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on August 30, 2013 , LexisNexis #0913-125

DeAngelis v. Holmes (In re Holmes)

Ruling
Case ordered converted or dismissed based on totality of circumstances including excessive and unreasonable budget.
Issue(s)
Should debtor's case be dismissed under the presumption of abuse due to failure to include household contributions of debtor's housemate or in the alternative pursuant to totality of circumstances.

ABI Membership is required to access the full summary of DeAngelis v. Holmes (In re Holmes) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on August 21, 2013 , LexisNexis #0913-057

In re Lorenzo

Ruling
Plan could not be modified to include newly listed expenses.
Procedural posture

Chapter 13 debtors filed a proposed third modified plan, seeking to reduce the payment to their unsecured creditors by $52,372.72 (from $141,972.32 to $89,599.60). The chapter 13 trustee objected to the modification as not in compliance with the Bankruptcy Code.

ABI Membership is required to access the full summary of In re Lorenzo Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on May 09, 2013 , LexisNexis #0613-062

In re Weinart

Ruling
Case dismissed due to presumption of abuse where personal savings plan loan repayment was not a proper expense deduction.
Procedural posture

The United States Trustee (UST) filed a motion to dismiss the debtor's chapter 7 bankruptcy case claiming that the presumption of abuse arose pursuant to 11 U.S.C.S. § 707(b).

ABI Membership is required to access the full summary of In re Weinart Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on April 11, 2013 , LexisNexis #0513-089

In re Sturm

Ruling
On remand, case dismissed for presumption of abuse due to improper deduction for expenses of mortgage solely in name of non-debtor spouse.
Procedural posture

On remand from the United States District Court for the Northern District of Ohio, the court reconsidered two matters pertaining to its prior decision in which, on a motion brought by the United States Trustee (UST), it was determined that, under the "means test" calculation of 11 U.S.C.S. § 707(b)(2), a presumption of abuse arose.

ABI Membership is required to access the full summary of In re Sturm Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on September 21, 2012 , LexisNexis #1012-134

In re Moose

Ruling
Civil Service Retirement System pension could not be deducted as "special circumstance and was required to be included in current monthly income calculation.
Procedural posture

This matter came before the court for a hearing on debtors' motion to strike presumption of abuse.

ABI Membership is required to access the full summary of In re Moose Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on March 20, 2012 , LexisNexis #0412-057

In re Williams

Ruling
Case dismissed as filed in bad faith where debtor purchased house on petition date.
Procedural posture

Movant, the trustee, asked the court to dismiss debtor's chapter 7 case on claims that it constituted an abuse of chapter 7 and was properly dismissed under either the so-called "means test" per 11 U.S.C.S. § 707(b)(2) or under the "totality of the circumstances" test in § 707(b)(3). Movant also argued that the case was filed in bad faith.

ABI Membership is required to access the full summary of In re Williams Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on March 19, 2012 , LexisNexis #0412-056

In re Wedblad

Ruling
Case dismissed for abuse pursuant to means test using IRS standards pursuant to §707(b)(2)(A), which did not unconstitutionally delegate legislative power to IRS.
Procedural posture

The United States Trustee filed a motion to dismiss chapter 7 debtors' case pursuant to 11 U.S.C.S. § 707(b).

ABI Membership is required to access the full summary of In re Wedblad Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on January 25, 2012 , LexisNexis #0212-093

In re Campbell

Ruling
Case ordered converted or dismissed for abuse absent evidence of special circumstances.
Procedural posture

The United States Trustee filed motion to dismiss chapter 7 debtor's case for abuse under 11 U.S.C.S. § 707(b). The debtor argued that he had rebutted any presumption of abuse by demonstrating "special circumstances" as required by § 707(b)(2)(B)(i).

ABI Membership is required to access the full summary of In re Campbell Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on January 19, 2012 , LexisNexis #0312-023