From the Editor – Dismissal and Conversion

By The Honorable William Houston Brown (Retired)

Case properly dismissed for failure to comply with credit counseling. Assuming the debtor’s alleged lack of funds to pay for credit counseling could be an exigent circumstance, the debtor did not demonstrate that he had applied for credit counseling and had been unable to obtain it within the required seven days. The requirements of § 109(h)(3) were not satisfied, and the case was properly dismissed. Taal v. Sumski (In re Taal), 504 B.R. 682 (BAP 1st Cir. 2014).

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The Honorable William Houston Brown . . .

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