From the Editor – Avoidance

By The Honorable William Houston Brown (Retired)

Section 547(c)(8) threshold applied. In a Chapter 13 case, one debtor’s employer withheld $858.98 as a result of prepetition wage garnishment, but the actual amount transferred to the judgment creditor was less than $600, with the remaining amount returned to the debtor after the creditor cancelled the garnishment. As a result, the aggregate amount was less than the $600 threshold of § 547(c)(8), preventing the avoidance of $572.78 transfer as a preference. Pierce v. Collection Associates, Inc. (In re Pierce), 504 . . .

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