Reported at 54 B.R. 910. The debtors' lack of disposable income – resulting from unremunerative employment and not from lack of effort – does not constitute an undue hardship, and therefore their student loans are not dischargeable under § 523(a)(8)(B)

The appropriate monthly adequate protection payment for a previously over-secured but now under-secured creditor is the amount of interest accruing on the debt each month, plus the amount by which the value of the collateral is declining each month

The owner of real property purchased at a county treasurer's tax sale is entitled to an administrative expense claim for post-petition taxes, and the plan should be amended to reflect the statutory interest rate on the tax claim as allowed by § 511(a).

A purchaser at a tax sale is subrogated to the rights of the county treasurer to collect from the debtor the amount of the taxes paid by the purchaser plus interest at the statutory rate until plan confirmation. Then interest accrues at the plan rate

Debtors' real property was sold at tax sale but the sale was not confirmed pre-petition. County sought relief from stay to confirm sale and transfer the property to a buyer. Motion was denied because debtors propose to use the property to reorganize

When debtors attempted to discharge their state income tax liability, state objected because no amended return was filed. Debtors' testimony about mailing the return, without more, was insufficient to overcome the presumption that it was not received

The debtor was alleged to have incurred a non-dischargeable debt for luxury goods and services shortly before filing bankruptcy. She did not respond to discovery, so each element of the case was deemed admitted and judgment was entered against her.

Debtor was co-guarantor on a bank loan. The bank could collect from debtor despite settling with the other guarantor & surrendering the promissory note. When the debt is fully paid, the co-guarantor's right to contribution from the debtor will mature

A mortgage lien secured by three tracts of land cannot be avoided, even if the claim is undersecured. The Dewsnup v. Timm line of cases does not require a creditor to give up any part of a lien that serves as security for its allowed secured claim

The creditor violated the automatic stay by filing a state court fraudulent conveyance action against pre-petition transferees of the debtors' property. The lawsuit was an attempt to recover on the creditor's claim, in violation of § 362(a)(6)