On the Chapter 13 trustee’s objection to exemptions – particularly to the debtor’s use of the Schedule C check box for “100% of fair market value, up to any applicable statutory limit” – the court ruled:

A debtor is not prohibited from using the 100% FMV Box. But the box should be used sparingly. If a debtor selects the 100% FMV Box, the debtor must ensure the trustee can determine the amount of the exemption claimed from Schedule C and the applicable statute. If a debtor creates an ambiguity in claiming an aggregate exemption more than one time, an objection to exemptions will be sustained.

The 100% FMV Box may have little to no value to a debtor. If a debtor uses the 100% FMV Box and the trustee objects, Schwab makes value an issue [and an evidentiary hearing with live testimony will be required].