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Americredit Fin. Servs. v. Lanier (In re Lanier)

Ruling
Proposed plan modification for surrender of vehicle in full satisfaction of debt pursuant to hanging paragraph did not violate Fifth Amendment.
Procedural posture

Objectant, a secured creditor, opposed debtor's motion to modify a confirmed chapter 13 plan to permit him to surrender a vehicle securing the claim as an alternative to obtaining the creditor's approval of the modification or to paying the claim through the plan. At issue was whether such a modification deprived the creditor of a property right without just compensation in violation of the Fifth Amendment of the United States Constitution.

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opinion summary, case decided on June 29, 2007 , LexisNexis #0907-119

Stapleton v. Talmadge (In re Talmadge)

Ruling
Debtors could not claim ownership expenses for vehicles owned free and clear and were not eligble under chapter 7.
Procedural posture

Movant United States trustee filed a motion to dismiss a petition which respondent debtors filed under chapter 7, claiming that the debtors were not eligible for chapter 7 relief.

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opinion summary, case decided on June 28, 2007 , LexisNexis #0807-082

Independent Mortg. Co. v. Porter (In re Porter)

Ruling
Confirmation denied where debtor failed to explain why delay in selling home until end of plan was necessary for successful reorganization.
Procedural posture

The debtors moved for confirmation of their amended chapter 13 plan.

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opinion summary, case decided on June 15, 2007 , LexisNexis #0807-091

Stapleton v. Baldino (In re Baldino)

Ruling
Non-filing spouse's income could be included in current monthly income calculation only to the extent contributed to household expenses.
Procedural posture

The United States Trustee ("UST") moved for reconsideration of the court's prior order denying the UST's motion to dismiss the debtor's case under 11 U.S.C. § 707(b)(3). The motion alleged that the court's opinion contained a manifest error of law by failing to consider income of the non-filing spouse which was not expressly dedicated to household expenses.

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opinion summary, case decided on June 14, 2007 , LexisNexis #0707-080

Gateway Access Solutions Inc. v. Nester (In re Gateway Access Solutions Inc.)

Ruling
Adequate protection payments for security interests in FCC lease conversion payments not required as rejection of underlying option contract rendered interests worthless.
Procedural posture

Movant bankruptcy debtor was permitted to reject a contract granting an option to purchase FCC leases from the debtor, and respondent creditors who held security interests in lease conversion payments under the contract asserted that their liens extended to proceeds from postpetition lease sales and that the creditors were entitled to adequate protection under 11 U.S.C. § 363(e) as a condition of the contract rejection.

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opinion summary, case decided on May 17, 2007 , LexisNexis #0707-040

CCI Constr. Co. v. Allfirst Bank (In re CCI Constr. Co.)

Ruling
Bank's departure from procedure in covering outstanding checks was not in ordinary course of business so that payments were preferential.
Procedural posture

Plaintiff, debtor in possession, filed a complaint to set aside several preferential payments by the debtor to defendant bank, its primary business lender, under the terms of 11 U.S.C. § 547(b) or in the alternative, for recovery of improper setoff pursuant to 11 U.S.C. § 553. The bank asserted that the payments were not avoidable as made in the ordinary course of business, under 11 U.S.C. § 547(c)(2).

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opinion summary, case decided on April 18, 2007 , LexisNexis #0807-104

Bierbach v. Wagner

Ruling
Payments on business loan secured by real property owned by debtor's fiancee were made in ordinary course of business and were not preferential.
Procedural posture

Appellant chapter 7 trustee filed an adversary action in the bankruptcy court seeking to recover, pursuant to 11 U.S.C. §§ 547(b), 550(a)(1), alleged preferential transfers that purportedly benefitted appellee, the chapter 7 debtor's fiancee. The parties filed cross-motions for summary judgment. The trustee appealed after the district court granted summary judgment to the fiancee.

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opinion summary, case decided on April 04, 2007 , LexisNexis #0507-064

United States v. Martinez

Ruling
IRS granted relief from stay to setoff tax refunds against tax liabilities.
Procedural posture

Movant IRS appealed the decision that permitted it to setoff respondent debtors'federal income tax refunds against prepetition taxes, but only against priority obligations. The district court remanded the matter to provide the court an opportunity to delineate the facts considered in limiting the setoff to the IRS's priority claim.

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opinion summary, case decided on March 07, 2007 , LexisNexis #0607-101

Stapleton v. Mundy (In re Mundy)

Ruling
Debts scheduled to become due may be deducted as expenses on Form B22A regardless of debtor's intent regarding payment or retention of collateral.
Procedural posture

Movant U.S. Trustee ("UST") sought to dismiss the bankruptcy petition of respondent debtor pursuant to 11 U.S.C. § 707(b)(2).

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opinion summary, case decided on March 01, 2007 , LexisNexis #0407-118

United States v. White

Ruling
Bankruptcy court erred in holding that IRS setoff rights were limited to amount of priority claim.
Procedural posture

Appellant IRS appealed from an order issued by the bankruptcy court, which held that appellee, debtors, automatic stay should be modified to permit the IRS to exercise its setoff rights against the refund of $3,148.00 to the extent of the priority claim of $1,780.52, and denied relief from stay for the excess amount. The case implicated 11 U.S.C. §§ 522 and 553.

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opinion summary, case decided on February 28, 2007 , LexisNexis #0507-055