Consumer Bankruptcy

$12 Million in Gambling Losses Made Taxes Nondischargeable for Five Years

Circuits are split on whether nonpayment of taxes alone establishes the ‘conduct’ requirement making taxes nondischargeable for having evaded payment of taxes.

Legislative Highlights February 2026

Congress Passes “Bankruptcy Administration Improvement Act” The House of Representatives passed (voice vote) S. 3424, the “Bankruptcy Administration Improvement Act of 2025,” 1 to double the compensation payable to chapter 7 trustees in no-asset cases, extend the sunset

Congress Needs to Fix the Mess Created by the Supreme Court in Lamie

Unlike debtors in chapter 13, chapter 7 debtors cannot pay counsel with estate property. There may be no workaround allowing chapter 7 debtors to pay counsel before filing for services to be performed after filing.

Collecting a Sanction May Be Enforced by Contempt Rather than Writ of Execution

A district court in New York affirmed Bankruptcy Judge Paek by holding that collection of a sanction for a stay violation doesn’t require a writ of execution under Federal Rule 69(a).

No Loopholes in Section 362(b)(21) Allowing Foreclosure Against an Ineligible Debtor

Even if a debtor is ineligible to file again under Section 109(g), another filing does create a stay, but it’s not applicable to enforcement of a lien against real property.
5th Circuit Jan 13, 2026

Fifth Circuit Rules on Judicial Estoppel, an Issue Before the Supreme Court This Term

Supreme Court will decide whether potential motive for nondisclosure invokes judicial estoppel, or whether there must be subjective intent by the debtor to conceal.

Honest, but Still Unfortunate? Ninth Circuit Defines Authority of Social Security Administration to Recoup Overpayments Following Chapter 7 Discharge

Honest, but Still Unfortunate?Ninth Circuit Defines Authority of Social Security Administration to Recoup Overpayments Following Chapter 7 Discharge By Mark A. Fink and Richard E. Willi III As the U.S. Supreme Court has stated, the Bankruptcy Code’s principal purpose is

Judgments Can Be Declared Nondischargeable Before They Are Entered

Dischargeability depends on the elements of the tort, not whether there was a judgment before bankruptcy.