1/18/19 the Treasury Department and the IRS issued final regulations and three related pieces of guidance, implementing the new qualified business income (QBI) deduction (section 199A deduction). The new QBI deduction, created by the 2017 Tax Cuts and Jobs Act (TCJA) allows many owners of sole proprietorships, partnerships, S corporations, trusts, or estates to deduct up to 20 percent of...
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By Henry E. Hildebrand, III, Chapter 13 Trustee for the Middle District of TN
Danielson v. Flores (In re Flores), 2012 WL 3803936 (9th Cir, Aug. 31, 2013) (Chen)
Debtors with no “projected disposable income” as calculated on Form 22C do not have a mandatory applicable commitment period and can propose Chapter 13 plans less than 60 months, even after Lanning.
Case Summary
The Flores’ had income above the median for their state and filed a Chapter 13 petition proposing a plan of 36 months with monthly payments of $148. The proposed plan would . . .
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