Critical Case Comment

By Henry E. Hildebrand, III, Chapter 13 Trustee for the Middle District of Tennessee

In re Knorr, 2013 WL 5550209 (Bankr. M.D. Pa. October 8, 2013) (Thomas)

Child care expenses may only be permitted as reasonable and necessary expenses if they are necessary to provide for a taxpayer’s health and welfare or the production of income; the court can permit a debtor a year to come into compliance with the IRM’s obligation to trim unnecessary expenses.

Case Summary

The Knorrs filed a Chapter 13 plan proposing to pay all of their Projected Disposable . . .

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