The Ninth Circuit split with the Sixth Circuit in the interpretation of the ‘hanging paragraph’ in Section 541(b)(7). Courts are divided four ways on whether or how much a ‘13’ debtor may contribute to voluntary retirement plans after filing.
Interpreting the hanging paragraph in Section 523(a), the Ninth Circuit sticks to the Beard test in deciding whether something is close enough to a tax return to justify discharging a tax debt.
