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northern district of alabama

In re Kirk

Ruling
Plan proposing to pay attorneys' and filing fees before paying creditors could not be confirmed.
Procedural posture

Chapter 13 debtors' plan did not comply with 11 U.S.C.S. §§ 1325(a)(3), (5)(B)(iii)(I), 1326(a)(1)(C), because it would pay attorney's fees and filing fees in full before any payments to creditors. The Court announced it would confirm the plan only if it modified to provide for payments to a purchase-money auto lender in equal monthly installments without being delayed. Counsel for the debtors objected and for confirmation without amendment.

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Consumer opinion summary, case decided on December 21, 2011 , LexisNexis #0212-066

Moore v. Alabama Dept of Revenue (In re Moore)

Ruling
State taxes were nondischargeable regardless of when assessed.
Procedural posture

Chapter 7 debtors filed an adversary proceeding against defendant Alabama Department of Revenue (ADOR). The parties disputed whether the debtors' taxes for 2007, 2008, and 2009 were nondischargeable under 11 U.S.C.S. § 523(a)(1). The parties each filed motions for summary judgment.

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Consumer opinion summary, case decided on November 14, 2011 , LexisNexis #1211-082

In re Kerley

Ruling
Administrative closing of case to prevent accrual of quarterly fees denied.
Procedural posture

Chapter 11 individual debtors sought to have their cases, which contemplated payments to creditors over time from post-confirmation earnings, administratively closed for the purpose of avoiding the payment of quarterly fees to the Bankruptcy Administrator under 28 U.S.C.S. § 1930(a) as well as voiding further monthly operating reports.

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Consumer opinion summary, case decided on November 04, 2011 , LexisNexis #1211-004

In re Dial

Ruling
Relief from stay denied, conditioned upon debtor making monthly payments and maintaining insurance on mortgaged property.
Procedural posture

A creditor filed a motion for relief from stay and from a co-debtor stay pursuant to 11 U.S.C.S. § 362(d).

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Consumer opinion summary, case decided on November 03, 2011 , LexisNexis #1211-006

In re Qimonda AG

Ruling
Debtor in foreign proceeding could not terminate U.S. patent licenses.
Procedural posture

The representative of a debtor in a foreign insolvency proceeding moved to eliminate or restrict the applicability of bankruptcy law to allow the representative to terminate U.S. licenses to use the debtor's patents under foreign law. Upon remand from the U.S. District Court for the Eastern District of Virginia, the bankruptcy court considered whether the right to retain the licenses under bankruptcy law should apply under 11 U.S.C.S. § 1506.

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Commercial opinion summary, case decided on October 28, 2011 , LexisNexis #1111-135

In re Beasley

Ruling
Confirmation denied and case dismissed due to lack of good faith by debtors two prior chapter 7 discharges.
Procedural posture

The court held a hearing on whether to confirm the debtors' Chapter 13 plan. Both the debtors and the Chapter 13 trustee submitted briefs in support of confirmation.

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Consumer opinion summary, case decided on September 27, 2011 , LexisNexis #1111-132

North Alabama Bank v. Brooks (In re Brooks)

Ruling
False joint financial statement by debtor and nondebtor spouse was properly relied upon by creditor resulting in nondischargeable debt.
Procedural posture

Plaintiff creditor sought a determination that debt owed it by defendant debtor was nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(B).

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Consumer opinion summary, case decided on September 19, 2011 , LexisNexis #1011-088

Smith v. Smith (In re Smith)

Ruling
Postpetition interest on child support debt was nondischargeable.
Procedural posture

A discharged chapter 7 debtor sought a declaration that unpaid interest on his child-support obligation was discharged in his chapter 7 bankruptcy case, and in particular that such interest was not excepted from discharge pursuant to 11 U.S.C.S. § 523(a)(5). Co-defendant, State of Alabama, Department of Human Resources (DHR), a state agency that collected delinquent child-support obligations, filed a motion for summary judgment.

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Consumer opinion summary, case decided on August 23, 2011 , LexisNexis #0911-104

In re Nwonwu

Ruling
Debtor's eighth chapter 13 case dismissed given inability to support plan.
Procedural posture

The chapter 13 trustee filed an objection to confirmation of the debtor's plan and a motion to dismiss the case for cause under 11 U.S.C.S. § 1307(c). A mortgage creditor filed a motion for relief from the automatic stay under 11 U.S.C.S. § 362.

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Consumer opinion summary, case decided on August 12, 2011 , LexisNexis #0911-097

In re Linton

Ruling
Plan paying 100 percent of joint unsecured creditors but only 5 percent of non-joint unsecured creditors confirmed.
Procedural posture

A chapter 13 trustee objected to the confirmation of a plan that proposed a 100 percent payment of unsecured claims on which the debtor and his non-debtor wife were jointly liable while only providing a 5 to 6 percent payout to non-joint unsecured creditors.

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Consumer opinion summary, case decided on July 27, 2011 , LexisNexis #0911-065