Memorandum Decision on Trustee's Objection to Confirmation
SUSAN V. KELLEY, Bankruptcy Judge.
Prior to the enactment of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA), there was little question that a Chapter 13 debtor's tax refunds constituted disposable income that were required to be dedicated to the Chapter 13 plan. However, BAPCPA changed the definition of "disposable income," and courts around the country are divided on...
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