In re DeHoog

Neither counseling received more than 180 days prior to petition date nor counseling completed later in the afternoon of the petition date satisfied credit counseling requirement.
Procedural posture: 
A debtor was ordered to show cause why her chapter 13 bankruptcy case should not have been dismissed for failure to comply with credit and budget counseling requirements of 11 U.S.C.S. § 109(h)(1) and (3).
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Consumer case opionion summary, case decided on September 17,2008, LexisNexis #0209-003