No “$200.00 Old Car” Deduction When Calculating Disposable Income

By Robert G. Drummond, Chapter 13 Trustee for the District of Montana

In the case of Drummond v. Luedtke (In re Luedtke), the Ninth Circuit Bankruptcy Appellate Panel held that debtors may not deduct a $200.00 “old car” deduction when calculating disposable income. The court recognized that the disposable income formula allows deductions for items included in the “National Standards and Local Standards ... issued by the Internal Revenue Service” contained in § 707(b)(2)(A)(ii)(I . . .

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