» Chapter 7 Bankruptcy

Court rejects "sufficiently rooted" test and holds bankruptcy estate does not include portion of bonus earned from prepetition employment

In In re Brown, Case No. 18-81242 (Bankr. C.D. Ill. May 9, 2019), Judge Perkins of the Central District of Illinois, concluded that property of the estate did not include that portion of a debtor’s annual bonus payable after the petition date that was related to prepetition employment. In the Brown case, the debtor filed a chapter 7 case on August 17, 2018 and was due to receive a bonus from Caterpillar in 2019 pursuant to a Short Term Incentive Plan (the “STIP”). The STIP bonus was calculated based upon work performed during 2018. The trustee argued 62.7% of the STIP bonus was property of the estate because “62.7% of the bonus is rooted in the pre-bankruptcy past.” Id. In ruling against the trustee, Judge Perkins rejected the “sufficiently rooted” test (discussed below) and concluded the STIP bonus was not estate property because the debtor did not have a pre-petition property interest in the bonus as a matter of Illinois law. Citing the seminal Whiting Pools, 462 U.S. 198 (1983), Judge Perkins first pointed out that Section 541 does not expand the rights of the debtor and instead the trustee succeeds to no greater rights than those held by the debtor on the petition date. Judge Perkins then noted that “uncertainty may arise when a property interest has its origins in the prepetition time frame but isn’t obtainable by the debtor until after bankruptcy, subject to the postpetition occurrence of one or more contingencies.” After recognizing the distinction between the occurrence of a contingency and the existence of an expectancy, Judge Perkins analyzed whether the “sufficiently rooted” test — which gained currency from a Bankruptcy Act case known as Segal v. Rochelle, 382 U.S. 375 (1966) (addressing whether tax refund was property of bankruptcy estate) — survived enactment of Section 541. Under the “sufficiently rooted” test, bankruptcy courts routinely determined whether a property right was “sufficiently rooted” in prepetition events as to make it a prepetition property interest, even when payable post-petition. Classic examples of such property interests include tax refunds, sales commissions and, of course, employment bonuses. Under the “sufficiently rooted” test, the STIP bonus probably would have been property of the estate because 62.7% of the amount related to prepetition employment services. Noting, among other authorities, that the Fifth Circuit expressly held that “the sufficiently rooted” test did not survive the enactment of Section 541 (citing In re Burgess, 438 F.3d 493, 498-99 (5th Cir. 2006)), and that the Seventh Circuit has expressed skepticism about the usefulness of the “sufficiently rooted” test even in the context of tax refunds (citing In re Meyers, 616 F.3d 626 (7th Cir. 2010)), Judge Perkins reasoned that “[i]f applicable state law provides that a potential property interest of a debtor was merely an expectancy as of the petition date, the expectancy is properly excluded from the estate without regard to whether the interest may be said to be “rooted” in the debtor’s pre-bankruptcy past.” Judge Perkins then analyzed Illinois law to determine whether a bonus plan created a right, subject to a condition, or merely an expectancy; ultimately concluding that “where an employer reserves the absolute discretion not to award a future bonus, the bonus is treated under Illinois law as an expectancy, not a present property interest.” From that premise, Judge Perkins had little difficulty concluding that the contract language determining the debtor’s entitlement to a bonus from Caterpillar “makes the bonus discretionary and disclaims any obligation to pay” and thus creates “only a bare expectancy interest. [Accordingly], [t]he Trustee takes no present property interest in any future STIP payments and no part of it can become property of the estate.” In the penultimate part of his analysis, Judge Perkins concluded that “[t]o consider the bonus to be property of the estate simply because it related to [the debtor’s] prepetition employment would be to give the bankruptcy estate more than the Debtor had on the petition date [and thus] the Debtor’s expectancy interest in the 2018 STIP bonus is not a legal or equitable interest in property as of the commencement of the case under section 541(a)(1) and is not an asset of her estate subject to the Trustee’s administration.” Id. If you would like more information regarding bankruptcy filings and would like to speak to one of our experienced attorneys, please call (312) 878-6976 or fill out a contact form here. Read More
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Discharge of debts in Chapters 7 and 13; important differences you should know

Through a Chapter 13 payment plan, a debtor may discharge multiple types of debt that cannot be discharged in a Chapter 7 bankruptcy (a liquidation). Thus, if you qualify for a Chapter 13 bankruptcy, and your debts would be nondischargeable in a Chapter 7, Chapter 13 may be a better option. The most common debts that can be discharged in Chapter 13 bankruptcy, but not in a Chapter 7 bankruptcy include: Debts arising out of willful and maliciously property damage: If a court finds you willfully or maliciously damaged another person’s property, the resulting debt cannot be discharged in a Chapter 7 bankruptcy. But you can discharge debts related to willful and malicious property damage in Chapter 13 bankruptcy. Willful or malicious acts that cause personal injury or death cannot be discharged in either a Chapter 7 or Chapter 13 bankruptcy.Tax Obligations: If you incur a debt to pay off nondischargeable tax obligations (such as paying your tax liability with a credit card), you can discharge that debt in Chapter 13 bankruptcy, but not in Chapter 7.Certain debts incurred in divorce or separation proceedings: Domestic support obligations, such as alimony or child support, cannot be discharged in either a Chapter 7 or a Chapter 13 case. However, other types of debts to your spouse, former spouse, or child through a divorce decree, property settlement, separation agreement, or other related proceeding, can be discharged in a Chapter 13 bankruptcy. Such dischargeable obligations typically include debts assigned to you in the course of divorce or separation proceedings (e.g., obligation to pay off a joint credit card debt).Certain fines and penalties owed to the government: Other than criminal fines, fines and penalties payable to the government are generally dischargeable in a Chapter 13 bankruptcy. In contrast, a Chapter 7 bankruptcy will not discharge most government fines and penalties.Debts denied discharge in a prior bankruptcy: If you filed for bankruptcy previously and the court denied your discharge, you can’t eliminate those same debts in a subsequent Chapter 7 bankruptcy. However, you may be able to discharge those in Chapter 13.  Loans against your retirement account: A loan against your retirement account can be dischargeable in Chapter 13 bankruptcy, but not in Chapter 7 bankruptcy. There are, however, reasons to keep repaying such loans in a Chapter 13 bankruptcy. The amount you are required to pay under Chapter 13 plan depends upon the amount of your disposable income. Repaying a loan against your retirement funds reduces the amount of your disposable income, so it often makes sense to keep repaying that loan because the payments benefit you while reducing the amount you are required to pay other creditors. The above are just some of the factors to consider when deciding whether a Chapter 13 bankruptcy makes sense for you. Feel free to contact our office for a free consultation to further discuss whether a Chapter 13 bankruptcy is right for you. Read More
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Discharge injunction violation results in $90,000 award

A recent case in the District Court, Romanucci & Blandin, LLC et al. v. Lempesis, affirmed a judgment by the Bankruptcy Court awarding $90,000 for an especially egregious violation of the discharge injunction, including damages for emotional distress and punitive damages. Spiro Lempesis, a former baseball coach, was sued by Anthony Collaro, one of his former players, with the help of Roamanucci & Blandin, a law firm. Lempesis filed for bankruptcy. But because of how the law firm dealt with the bankruptcy filing and eventually with the discharge injunction, the law firm wound up owing the defendant money. The filing of a bankruptcy case creates an automatic stay, stopping all collections actions in favor of the debtor. Not only are actions taken in violation of the automatic stay void, there are consequences for violating the stay. Generally, a plaintiff in a lawsuit has to seek relief from the stay in the bankruptcy court before proceeding in any other court. In addition to providing the debtor with a breathing spell, the stay helps to channel lawsuits into the bankruptcy court so the bankruptcy court can provide air traffic control. The discharge injunction provides the debtor with permanent protection against lawsuits for pre-petition conduct. While there are exceptions to both the automatic stay and the discharge, an order from the bankruptcy court is often required. Here, after the bankruptcy was filed, notice was sent to the law firm, but the mail was returned because the law firm had moved. So Lempesis’s bankruptcy lawyer faxed it to the law firm, where an associate put it in the file, but apparently didn’t tell anyone else at the law firm about it. Lempesis received a discharge. The lawsuit was voluntarily nonsuited and later refiled (a common strategy in Illinois courts, used by plaintiffs to buy time when the statute of limitations is looming). Even after Lempesis moved to enforce the discharge and for sanctions, the law firm continued to pursue Lempesis in the state court lawsuit, and even went on TV to repeat the allegations. The bankruptcy court eventually awarded $90,000 in damages: $11,000 in attorneys’ fees and costs, $12,000 in emotional distress damages, $50,000 in punitive damages, and $17,000 of additional attorney’s fees based on a supplemental statement of fees, presumably required to bring the discharge injunction litigation to trial. This award was appealed to the district court, which affirmed the whole award against the firm, but vacated the award against the client. Things did not have to turn out this way. If the notice of bankruptcy had not been ignored, it would have been possible to ask the bankruptcy court’s permission to continue with the lawsuit, and to keep any claim against Lempesis alive despite the discharge. Based on the facts we know from the court opinions, it would have been worth a shot to seek denial of the dischargeability of Collaro’s claim. But by the time Lempesis sought relief of his own, that boat had sailed. The law firm also ran up damages by pursuing the lawsuit even after the motion for sanctions was filed. Discharge injunction litigation is for all intents and purposes a lawsuit in federal court, and lawsuits in federal court are expensive. One aspect of the punitive damages was judge’s conclusion that a lawyer should have known better. Of course, not all lawyers need to know the nuances of  how the discharge works, but  they should all know to proceed with caution. Even so, it is also necessary to proceed quickly. Damages for a violation of the stay can multiply as time goes on. The deadline for seeking a dischargeability determination comes and goes quickly, and can only be extended before the time expires. It is important for a lawyer to be educated about these potential consequences, or to have experienced bankruptcy counsel on the team so as to not run afoul of the automatic stay and the discharge injunction, and to preserve client rights considering fast and inexorable bankruptcy deadlines. Read More
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The Means Test: Do I Automatically Qualify For Chapter 7 Bankruptcy?

Many individuals are still financially struggling to recover from what has been described as one of the worst economic climates since the great depression of the 1930’s. In this current era of financial hardship, Chapter 7 Bankruptcy is seen as an alternative for individuals unable to find a solution to their debt problems. Chapter 7 Bankruptcy, otherwise known as straight liquidation, is where assets not protected by the law are collected by the trustee and sold to pay all or part of what is owed to the creditors. Unlike Chapter 13 Bankruptcy, there is no repayment plan in Chapter 7 Bankruptcy. Once the trustee sells your unprotected assets, your remaining outstanding debts are discharged. Prior to October 17, 2005, Bankruptcy Judges were largely responsible for determining whether or not a debtor met Chapter 7 filing requirements. When President Bush signed into law “The Bankruptcy Abuse Prevention and Consumer Protection Act,” debtors were automatically deemed eligible to file Chapter 7 Bankruptcy if they met certain criteria, in particular the means test.  Failure to meet the new criteria, forces the Bankruptcy Court to convert the Chapter 7 case into a Chapter 13 case. Below you will find the means test criteria, which must be met in order for you to be automatically eligible to file Chapter 7 Bankruptcy: The Bankruptcy Means Test This test is used in order to determine your automatic Chapter 7 Bankruptcy eligibility. If your current yearly income is less than the median income for the household of your size in your state, you pass the means test.  Bankruptcy law determines your income by looking at your household income during the six full calendar months before your Bankruptcy filing. The following are the median yearly amounts for the state of Illinois: Household of 1: $47,485 Household of 2: $59,861 Household of 3: $68,721 Household of 4: $80,776 For Each Additional Dependent Member In the Household: Add $8,100[i] **It should be noted, that if your debts are primarily business debts, then you will not be subject to the means test and will automatically qualify for Chapter 7 Bankruptcy. If you pass this test, then you are automatically eligible to file Chapter 7 Bankruptcy. If your household income exceeds the state median, DON’T BE ALARMED, YOU CAN STILL QUALIFY TO FILE CHAPTER 7 BANKRUPTCY.  In order to determine if you are still able to file Chapter 7 Bankruptcy after not passing the test above, complex computations need to be made in order to assess your potential Chapter 7 Bankruptcy eligibility. These complex computations are aimed at calculating your monthly disposable income. These calculations involve determining your allowed expenses. These allowed expenses vary from county to county and household size. Some of the expenses commonly allowed are for example: grocery expenses, mortgage payments, and transportation expenses.   There can potentially be a big difference between filing Bankruptcy in Chicago and filing Bankruptcy in Joliet. Free Consultation with a Chicago Bankruptcy Attorney Bankruptcy is a complex process. Whether you think you are not eligible for Bankruptcy, earn too much money, or just need to hear advice, contact us! For more information about Bankruptcy requirements contact one of our distinguished Chicagoland Bankruptcy attorneys at the Law Office of William J. Factor! [i] http://www.justice.gov/ust/eo/bapcpa/20130401/bci_data/median_income_table.htm Read More
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Chapter 20 Bankruptcy Explained

Most individuals have heard or read about Chapter 7, 11 or 13 Bankruptcy. With big cities such as Detroit filing Bankruptcy, Chapter 9 Bankruptcy (municipality restructuring) has become a more mainstream term. Chapter 12 Bankruptcy also exists, but is mainly just a form of reorganization for farmers and fishermen. Oddly enough, nowhere in the Bankruptcy code is there anything actually called Chapter 20 Bankruptcy. Although not expressly mentioned in the Bankruptcy Code, Chapter 20 Bankruptcy  is a real thing. Filing Chapter 20 Bankruptcy in Chicago Chapter 20 Bankruptcy is a colloquial term given to a situation where a debtor files Chapter 7 and Chapter 13 Bankruptcy back-to-back (7+13=20). It should be noted that Chapter 20 Bankruptcy is not a common occurrence, it’s a unique strategy that we can offer in the right circumstances, particularly for homeowners who owe more than their home is worth. Although most debts can be discharged by filing Chapter 7 Bankruptcy, some debts will remain. Some examples are domestic obligations, tax debts, student loans and mortgages on your home. The first step of Chapter 20 Bankruptcy is filing Chapter 7 Bankruptcy. When a debtor files Chapter 7 Bankruptcy, if the mortgage isn’t paid, whether it is your first or second mortgage on your home, the creditor will have the right to foreclose on your home. This foreclosure can take place immediately after the Bankruptcy is completed or if the creditor obtains special permission from the Bankruptcy court. These mortgages remain on your home notwithstanding your Chapter 7 discharge because they are secured obligations against you and the home. Someone who wants to pay the debts financing the purchase of their home in order to keep the property must act quickly if they are behind on their payments. Thus, a subsequent filing of a Chapter 13 Bankruptcy case is taken as the next step in order to reduce that loan amount to the fair market value of the property. This creates an unsecured obligation that is removed from the property with a Chapter 13 Bankruptcy discharge, this is what is known as lien stripping. An example of Lien Stripping is when a homeowner has a home mortgage principle balance of $125,000, along with a second mortgage of $25,000. The home in this example is currently valued at $100,000 in the market. Although there is not enough equity in the home to secure the second mortgage, it could possibly be stripped or removed as a secured attachment from the home in a chapter 13 case and instead become a unsecured debt. This is very important because unsecured debts can be restructured in a Chapter 13 payment plan, and are eligible to be discharged once the payment plan is complete. We often recommend this approach to individuals and families who have a tremendous amount of unsecured debt and who are behind on mortgage payments as well. The goal of Chapter 20 Bankruptcy is to discharge as much debt as possible. When Chapter 7 Bankruptcy is filed and discharge is granted, we can then establish a sustainable repayment plan through Chapter 13 Bankruptcy to help you stay afloat on the debts that survive the initial Chapter 7 Bankruptcy discharge. Schedule a Free Consultation with our Chicago and Northbrook Bankruptcy Attorneys Chapter 20 Bankruptcy is a complex strategy because it involves two separate Bankruptcy actions. With the right legal assistance, this strategy can be a viable and beneficial one.  Don’t hesitate, pick up the phone and call us at (312) 878-6976 for your free, no obligation consultation!! Read More
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Top 5 Bankruptcy Myths Debunked

Bankruptcy has many misconceived stigmas to it. Frankly, there is a lot of misinformation out there, and much of the stereotypes regarding Bankruptcy are just not true. With just over One Million people declaring Bankruptcy as of the 12 month period ending on September 30, 2013, you are not alone in this process.[i] With Bankruptcy folklore continuing to emerge, our Chicago bankruptcy attorneys want to debunk some of these popular myths for your sake. Bankruptcy does not have to be a scary process, and we hope that this article helps clear some of the misconceptions you might have read or heard. 1.  You Must Be Broke Before Filing Bankruptcy A very common misconception. You should not wait until an emergency with bank restraints or until your home is getting foreclosed on to file Bankruptcy. A good rule of measure is to look where you will be financially six months from now. If for worse, then Bankruptcy might be worth looking into. 2. Bankruptcy Will Discharge All Debts NO! There are certain debt obligations that are nearly impossible to discharge. A great example is domestic support obligations (i.e., Child Support and Alimony).  Also, as a result of the Bankruptcy Abuse Prevention and Consumer Protection Act (BAPCPA) of 2005, student loans fall in a similar category as domestic support obligations. Student loans can be forgiven if you are able to prove hardship, such as a permanent disability, but even that standard is nearly impossible to meet. 3. If I File Bankruptcy, I Will Lose Everything I Own If you file Chapter 13, you actually get to hang on to all your assets as long as you remain current in your payment plan. If you file Chapter 7, most exemptions provided in the State you file will let you keep your valuable assets. Our distinguished attorneys at the Law Office of William J. Factor are more than happy to discuss how your valuable assets can be protected in Bankruptcy. 4. Only Financially Irresponsible Individuals File Bankruptcy Definitely not true! Did you know Donald Trump filed Bankruptcy? Heck, even Mark Twain, one of America’s greatest authors, filed Bankruptcy. Unexpected-life changes always happen such as job loss, divorce, serious illnesses, etc. The Bankruptcy code was enacted to protect the “unfortunate but honest debtor,” with the idea of giving a new opportunity in life and a clear field for future effort, unhampered by the pressure and discouragement of preexisting debt. Bankruptcy is meant to give you the fresh start you need! 5. I Can Only File Bankruptcy Once In My Lifetime This popular myth is also not true.  If you have received a discharge in a previous Bankruptcy proceeding, that does not preclude you from filing again in the future.  If you received your first discharge under a Chapter 7 Bankruptcy, you cannot receive a second discharge in any Chapter 7 case within eight years from the date that the first Bankruptcy was filed. If you received your first discharge under Chapter 13, you cannot receive a second discharge in any Chapter 13 case that is filed within two years form the date that the first Bankruptcy was filed. Schedule a Free Consultation at (312) 878-6976 to Speak with a Chicago Bankruptcy Attorney There are many more common misconceptions out there. Before you decide to take the leap into Bankruptcy, consult one of our distinguished Chicagoland bankruptcy attorneys at the Law Office of William J. Factor, and learn the facts about how Bankruptcy will affect you. At the Law Office of William J. Factor we pride ourselves in having the “Big Firm Expertise at Reasonable Rates.” Don’t hesitate, pick up the phone and call us at (312) 878-6976 for your free, no obligation consultation!! [i] http://www.uscourts.gov/uscourts/Statistics/BankruptcyStatistics/BankruptcyFilings/2013/0913_f2.pdf   Read More
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Full Disclosure: Why It's Important to Tell Your Chicago Bankruptcy Attorney EVERYTHING When Filing Bankruptcy

The decision to file bankruptcy is a difficult one for most people, and it requires disclosure of a tremendous amount of information. The temptation can be great to hold back in some areas, just to feel like one is retaining a little bit of control. Perhaps there’s some jewelry that was just received as a gift, or an inheritance that is expected soon. Will what your lawyer doesn’t know hurt him? Maybe not–but it will very likely hurt you. Whether you are filing Chapter 7 or Chapter 13 bankruptcy, failure to accurately disclose every detail of your financial situation can come back to haunt you in a number of very serious ways. Just because you don’t tell doesn’t mean they can’t find out You may think that holding something back from your attorney means that the information is a secret. The reality is that bankruptcy trustees are skilled in looking for hidden assets, and technology has made it easier than ever. Many trustees and their staff regularly make use of social media to discover information that might not have made it onto the bankruptcy schedules. Even if you think your social media accounts are locked up tight, they’re probably not as private as you think. And you have no control over what other people’s privacy settings, and what they share about you. If you’re in a Chapter 7 case, and your best friend tags you in a picture with your new X-Box  or iPad you “forgot” to disclose, there could be trouble. If you’re in a Chapter 13, and a friend congratulates you on that new freelance gig you neglected to mention to your lawyer or the trustee, you are going to have some explaining to do. Tell the truth–or face the consequences If you fail to disclose assets, at the very least, you may be denied a discharge of certain debts. At worst, you could face jail time. Here are some of the possible consequences for failure to disclose information in a bankruptcy case: Your discharge will be denied, meaning that whatever debts you hoped to erase by filing bankruptcy will have to be paid in full. Even if you file a subsequent bankruptcy, you will not be able to discharge debt identified in a previous case where you failed to disclose assets. Your bankruptcy case may not be dismissed, meaning that even though your discharge is denied, the trustee can still collect and liquidate your assets to pay your creditors. If you’ve already received a discharge, it can be revoked. A bankruptcy discharge does not close the bankruptcy case. A discharge that has been granted can be revoked up until the case is closed, and in some cases, even after the case is closed. You could go to jail–for years. When you sign your bankruptcy schedules, it’s just like testifying to information in court: you are under oath. Misrepresenting or failing to disclose could lead to a perjury conviction, subjecting you to up to five years’ imprisonment and up to hundreds of thousands of dollars in fines. There is nothing to be gained by holding information back from your attorney. Don’t think of your lawyer as one more person trying to catch you with your hand in the cookie jar. Instead, realize that he’s trying to help you keep as many “cookies” as he legally can, so you can enjoy them without forever having to look over your shoulder. Schedule a Consultation with Our Chicago or Northbrook Bankruptcy Attorneys If you’re contemplating filing bankruptcy, contact our office today to learn how we can help you to protect as many assets as possible. Read More
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What NOT to Do Before Filing Bankruptcy

Most people who file a Chapter 7 or Chapter 13 bankruptcy have done everything they could to avoid filing, or even consulting with a bankruptcy attorney. People take pride in being to solve their own financial problems. Unfortunately, sometimes their honest attempts to do what they think is best end up jeopardizing their chance for a financial fresh start. Here are some things that you should NOT do if bankruptcy is a possibility in your near future–even if they initially seem like a good idea. Don’t spend down your retirement accounts. When there are piles of bills to be paid, the temptation to borrow from your 401(k) or other retirement accounts in an attempt to stave off bankruptcy is great. After all, it’s your money, it’s just sitting there, and you need it now. Why you shouldn’t do it: Borrowing from, or completely liquidating, your retirement accounts may not be enough to prevent an eventual bankruptcy. If you leave those funds where they are, they will very likely be exempt in a bankruptcy–meaning that when your debt is gone, you’ll still have your retirement funds. Also, if you do take money from retirement accounts, there may be stiff penalties and taxes that cannot be discharged in bankruptcy. Last but not least, those funds won’t be available when you really need them. Don’t sell or give away property to friends or family. Another temptation when the possibility of bankruptcy looms is to raise funds by selling your property, or to protect it by giving it to a family member for safekeeping. You get some much-needed cash, and your brother gets your motorcycle for a great price. It seems like a win-win. Why you shouldn’t do it: Bankruptcy trustees are highly suspicious of transfers of property to friends or family, especially if fair market value was not received for the items. The trustee might undo the transfer. Worse, you may be found to have intentionally committed fraud and have your bankruptcy discharge denied. Worst of all, criminal charges for fraud might be brought against you. Don’t repay family or friends money you owe them. You don’t have much cash on hand, and bankruptcy seems like a likely option. Shouldn’t you use what little you have to repay your mother for those few months’ rent she gave you the money for? It seems like the honorable thing to do. Why you shouldn’t do it: If you’re looking at a bankruptcy, your mom isn’t the only one to whom you owe money. The bankruptcy courts don’t permit debtors to give one creditor preferential treatment over others. The trustee has the right to reclaim preferential payments and redistribute them. Don’t run up your credit card bills. You know you shouldn’t, but you also know that once you file bankruptcy, you’re not going to be able to use your cards, and there are some things you really want. The credit card debt is going to be discharged in bankruptcy anyway; you’re just adding a little more. Is it really such a problem to do a little extra spending before you give up your cards? Why you shouldn’t do it: People who ran up credit card debt, then tried to have it discharged in bankruptcy, inspired some 2005 changes to the Bankruptcy Code. These changes, aimed at preventing such abuses, lowered the threshold for “luxury” purchases, and extended the period prior to the bankruptcy filing in which purchases are most carefully scrutinized. If the trustee finds that you ran up debt you didn’t intend to repay, he or she may not allow that debt to be discharged, and you’ll be on the hook for it. There are more “don’ts,” and many “dos,” to observe when considering bankruptcy. Don’t decide on your own. Call our Chicago bankruptcy firm for a consultation. Read More
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