From the Editor

By Wm. Houston Brown

Dismissal - Employer’s housing loan was not consumer debt for purposes of § 707b)(1). Affirming denial of § 707(b)(1) dismissal for abuse, the Ninth Circuit agreed with the bankruptcy court’s determination that a housing loan made by the Chapter 7 debtor’s former employer was not a consumer debt under the facts of this case. The loan was a key part of a compensation package, incurred “primarily for the non-consumer purpose connected to furthering [the debtor’s] career.” Determination of the debtor’s purpose for . . .

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