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§ 707(b)(2)

In re Smith

Ruling
401(k) plan loans were not secured debts for which repayment was required or special circumstances.
Procedural posture

The U.S. Trustee filed a motion to dismiss debtors' chapter 7 case pursuant to 11 U.S.C.S. §§ 707(b)(1) and (b)(2), asserting that one debtor's loans from his retirement savings plan were not secured debts or a special circumstance so as to defeat the presumption of abuse that otherwise arose.

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Consumer opinion summary, case decided on June 20, 2008 , LexisNexis #0708-123

In re Watkins

Ruling
Debtor not entitled to standard vehicle ownership expense deduction for vehicles owned free and clear.
Procedural posture

The United States Trustee asserted that bankruptcy debtors, in calculating their monthly disposable income, improperly claimed vehicle ownership expenses for vehicles which they owned free and clear of liens, and expenses for repayment of a loan from an employee retirement plan. The Trustee moved to dismiss the debtors' case under 11 U.S.C.S. § 707(b)(2)(A) based on the presumption of abuse of chapter 7 bankruptcy.

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Consumer opinion summary, case decided on June 18, 2008 , LexisNexis #0708-124

Hildebrand v. Kimbro (In re Kimbro)

Ruling
Bankruptcy court properly allowed debtors to deduct vehicle ownership expense for unencumbered vehicle.
Procedural posture

Appellant trustee sought review of the judgment of the bankruptcy court, which rejected the trustee's objection under 11 U.S.C.S. § 1325 to the chapter 13 plan and allowed appellee debtors to deduct vehicle ownership expense amounts in the applicable local transportation standards, pursuant to 11 U.S.C.S. § 707(b)(2)(A)(ii)(I).

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on June 12, 2008 , LexisNexis #0708-050

In re Smale

Ruling
Payments on property to be surrendered could be deducted in calculating monthly disposable income.
Procedural posture

The trustee moved to dismiss the debtor's chapter 7 case pursuant to 11 U.S.C.S. § 707(b)(2). The issue was whether the debtor could deduct, from his monthly disposable income, scheduled monthly payments for three of the four motor vehicles which he owned, but which he intended to surrender, or whether the presumption of abuse arose because the payments were not deductible.

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Consumer opinion summary, case decided on June 09, 2008 , LexisNexis #0708-051

In re Zabringer

Ruling
Student loan payments were not "special circumstances" that could be deducted from projected disposable income calculation.
Procedural posture

A trustee objected to confirmation of a debtor's amended chapter 13 plan on the ground that it did not provide for all of the debtor's projected disposable income, pursuant to 11 U.S.C.S. § 1325(b)(1)(B).

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Consumer opinion summary, case decided on May 30, 2008 , LexisNexis #0708-086

In re Comstock

Ruling
Case was not presumptively abusive where second vehicle in question was necessary for commuting as older vehicle was unreliable.
Procedural posture

The United States Trustee moved to dismiss the debtor's chapter 7 case pursuant to 11 U.S.C.S. § 707(b)(2) on the grounds that the filing was presumptively abusive. The sole remaining issue for the court to decide was whether the debtor's second automobile was necessary for the production of income or her health and welfare.

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Consumer opinion summary, case decided on April 30, 2008 , LexisNexis #0608-084

In re Hays

Ruling
Plan confirmation denied due to debtors' inclusion of expenses for adult daughter and fiance in means test calculation.
Procedural posture

A trustee objected to confirmation of the debtors' chapter 13 plan.

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Consumer opinion summary, case decided on April 29, 2008 , LexisNexis #0608-016

In re Law

Ruling
Confirmation denied due to improper deductions on Form 22C including expenses for unencumbered vehicle.
Procedural posture

Debtor's chapter 13 matter was before the court on the trustee's objection to confirmation of plan.

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Consumer opinion summary, case decided on April 24, 2008 , LexisNexis #0508-085

In re Parulan

Ruling
Loss of overtime did not constitute a special circumstance that would warrant an adjustmet to debtor's disposable income.
Procedural posture

A trustee in a bankruptcy case objected to confirmation of the bankruptcy debtor's plan on the ground that the plan failed to apply all of the debtor's projected disposable income to payment of unsecured claims. The debtor asserted that special circumstances based on loss of overtime work warranted an adjustment to disposable income under 11 U.S.C.S. § 707(b)(2)(B).

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Consumer opinion summary, case decided on April 22, 2008 , LexisNexis #0608-086

In re King

Ruling
Debtor could not deduct court ordered payments in spouse's own bankruptcy from current monthly income.
Procedural posture

A debtor filed for relief under chapter 7 of the United States Bankruptcy Code. The U.S. trustee filed a motion to dismiss the chapter 7 case as abuse.

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Consumer opinion summary, case decided on April 18, 2008 , LexisNexis #0608-085