From the Editor – Conversion and Dismissal

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By The Honorable William Houston Brown (Retired)

Marital adjustments for non-debtor spouse’s expenses disallowed. The United States Trustee moved to dismiss Chapter 7 case of one spouse under § 707(b), alleging improper marital and other adjustments under the means test. The non-filing spouse’s income is only excluded from the debtor’s disposable income “to the extent that the income is used to pay non-household expenses, i.e., expenses that are purely personal to the non-debtor spouse.” The non-debtor spouse earned more than the debtor, and the debtor . . .

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