By The Honorable John P. Gustafson, United States Bankruptcy Judge, Northern District of Ohio (Toledo)
XIX. EXEMPTIONS VS. INCOME – A CAGED DEATH MATCH.
A. Income Is Income - Even If It Is Exempt.
Prior to the passage of BAPCPA, there was a significant minority of courts that – to some extent – allowed exemptions to reduce or eliminate disposable income, relying on the language of Section 522(c). See, In re Berger, 61 F.3d 624 (8th Cir. 1995)(holding in a Chapter 12 case that disposable . . .
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