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From the Editor – Confirmation and Effect
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By The Honorable William Houston Brown (Retired)
Failure to include live-in girlfriend’s income on Schedule I was not bad faith. Declining to equate a live-in significant other with a non-filing spouse for purposes of the Code, Schedules and Form 22C, the debtor’s failure to include the person’s income on Schedule I did not establish bad faith in the plan proposal. The trustee did not show that the girlfriend was legally obligated to financially contribute to the joint household. Case law about such income is largely in the context of eligibility . . .
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