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The Third Circuit lauded Bankruptcy Judge Craig Goldblatt for a ‘well-reasoned’ opinion correctly interpreting Supreme Court authority.

Bankruptcy Judge Klinette H. Kindred declined to expand Bartenwerfer by imputing fraud or larceny when the debtor wasn’t a partner or agent.

Disputing the Fourth Circuit line by line and raising the possibility of a circuit split, the BAP and six bankruptcy courts have held that there’s no such thing as nondischargeability for corporate Sub V debtors.