From the Editor

By Wm. Houston Brown, United States Bankruptcy Judge (Retired)

Confirmation - Debtors could not deduct ownership costs for vehicle secured by non-purchase money lien. The above-median debtors claimed ownership deduction of $497 from projected disposable income, when the title loan payments on the vehicle were only $66.67. The difference in these amounts meant unsecured creditors could receive $25,819.80 over the 60-month plan, and the trustee objected to confirmation. Reviewing In re Ransom, 562 U.S. 61 (2011), for “what constituted an applicable vehicle ownership expense under the IRS Local . . .

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