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Fagan v. Collection Div. (In re Fagan)

Ruling
Taxes owed to state pursuant to International Fuel Tax Agreement were excise taxes on transactions and nondischargeable.
Procedural posture

Chapter 7 debtors filed a complaint against Collection Division, State of Michigan Department of Treasury (State), alleging that the international fuel tax owed by the debtor wife to the State was not within the non-dischargeablity exception of 11 U.S.C.S. § 523(a)(1). The State filed a motion to dismiss.

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Consumer opinion summary, case decided on February 14, 2012 , LexisNexis #0312-006

Gold v. Pasternak (In re Harvey Goldman & Co.)

Ruling
Trustee could avoid security interest of living trust in debtor's property.
Procedural posture

Plaintiff Chapter 7 trustee filed an adversary proceeding against defendants, two individuals who served as trustees of an irrevocable living trust, seeking a determination, inter alia, that he was entitled under 11 U.S.C.S. § 544 to avoid a security interest the trust held in property that belonged to a corporation's Chapter 7 bankruptcy estate. The Chapter 7 trustee filed a motion for summary judgment.

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Commercial opinion summary, case decided on September 13, 2011 , LexisNexis #1011-018

Gold v. Rubin (In re Harvey Goldman & Co.)

Ruling
Payment made by debtor more than 90 days prior to petition date to non-insider was not preferential.
Procedural posture

Plaintiff Chapter 7 Trustee filed an adversary action seeking to recover certain payments alleged to have been made by the debtor to defendant as a preferential transfer under 11 U.S.C.S. § 547(b). Defendant filed a motion to dismiss the adversary proceeding as to a $22,000 payment made more than 90 days before the filing of the petition.

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Commercial opinion summary, case decided on August 24, 2011 , LexisNexis #0911-055

Simon v. Gerdau MacSteel Inc. (In re American Camshaft Specialties Inc.)

Ruling
Avoidance proceeding failed where facts showed payments were made in the ordinary course of debtor's business.
Procedural posture

Chapter 7 trustee filed this adversary proceeding under 11 U.S.C.S. § 547(b) to avoid preferential transfers alleged to have been made to defendant transferee. The transferee filed two motions for summary judgment based upon affirmative defenses pursuant to § 547(c)(2) (ordinary course of business defense), and § 547(c)(4) (subsequent new value defense) raised in its answer to the complaint.

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Commercial opinion summary, case decided on February 09, 2011 , LexisNexis #0311-020

In re Senczyszyn

Ruling
Taxes due on return filed prior to petition date were not a postpetition debt.
Procedural posture

This matter was before the court upon an objection filed by the State of Michigan to a proof of claim filed by the debtors for 2008 income taxes owed by the debtors to the State of Michigan in the amount of $ 1,900.

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Consumer opinion summary, case decided on April 07, 2010 , LexisNexis #0610-083

In re Chubb

Ruling
Proof of claim containing debtor's "personally identifiable information" stricken without prejudice to amended filing.
Procedural posture

The creditor filed a proof of claim in the amount of $ 523.61 with attachments that contained the debtor's name, billing address, service address and a twelve-digit account number. The chapter 13 trustee filed an objection to the proof of claim as violative of Fed. R. Bankr. P. 9037(a) and the Gramm-Leach-Bliley Act, 15 U.S.C.S. § 6801(a).

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Consumer opinion summary, case decided on March 15, 2010 , LexisNexis #0510-031

In re Griswold Bldg. LLC

Ruling
Confirmation denied where proposed interest rate was too low, debtor lacked ability to make payments and plan was not "fair and equitable."
Procedural posture

Debtor limited liability companies filed petitions under chapter 11 of the Bankruptcy Code and a combined joint plan for reorganizing their businesses. An administrative agent for two banks that loaned the debtors money opposed confirmation of the debtors' third amended plan.

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Commercial opinion summary, case decided on December 07, 2009 , LexisNexis #1209-132

Simon v. ASIMCO Techs. Inc. (In re American Camshaft Specialties Inc.)

Ruling
Substantive consolidation of debtors and related corporation denied where separation of the respective assets and liabilities was not impossible.
Procedural posture

Plaintiff bankruptcy trustee brought an adversary proceeding against defendants, bankruptcy debtors, related corporations, and directors of the debtors, alleging inter alia that the directors breached fiduciary duties and that substantive consolidation of the debtors and the corporations was warranted. The directors moved to dismiss the breach of fiduciary duty claim, and the debtors and the corporations moved to dismiss the consolidation claim.

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Commercial opinion summary, case decided on September 01, 2009 , LexisNexis #0909-137

Morganroth v. Morganroth PLLC v. Stollman (In re Stollman)

Ruling
Fees owed by debtor to divorce lawyer were nondischargeable to extent relating to deliberate breach of agreement.
Procedural posture

Plaintiffs, two law firms and an accounting firm, sought summary judgment on claims that fees owed to them by reason of services rendered to defendant, a chapter 7 debtor, during her prepetition divorce were nondischargeable under 11 U.S.C.S. § 523(a). Plaintiffs also objected to discharge under 11 U.S.C.S. § 727.

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Consumer opinion summary, case decided on April 10, 2009 , LexisNexis #0809-120

In re Plastech Engineered Prods.

Ruling
Section 502(d) does not apply to disallowance of administrative expenses under 503(b)(9).
Procedural posture

Debtor objected to the 11 U.S.C.S. § 503(b)(9) motions for administrative expenses filed by numerous parties.

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Commercial opinion summary, case decided on September 16, 2008 , LexisNexis #1008-042