In a highly contentious issue, the Texas based Zamora Court Post-Petition condominium assessments are postpetition debts – and therefore non-disharageable.
Homeowners association fees assessed after the filing of a voluntary petition in bankruptcy are postpetition debts. See In re Beeter, 173 B.R. 108 (Bankr. W.D. Tex. 1994) (under the debtor’s condominium declaration, and under Arizona law, the covenant to pay assessments runs with the land; each new month’s ownership carries with it a new personal liability, arising out of the equitable servitude that burdens that ownership).
Attorney’s fees incurred to collect postpetition condominium assessments are themselves a postpetition debt.
In re Zamora, 2012 WL 4501680 (Bankr. W.D. Tex., Sept. 28, 2012)