As reported by Robin Miller of CBAR, any increase in the cash surrender value of the Chapter 13 debtor’s life insurance policy was neither income nor projected disposable income. Courts have repeatedly held that “[o]nly regular income and substitutes therefor can be counted in the determination of disposable income for the purposes of the chapter 13 test.” See In re Burgie, 239 B.R. 406 (9th Cir. B.A.P. 1999).
In re Brown, 2014 WL 4793243 (Bankr. E.D. Wis., Sept. 24, 2014)
(case no. 2:13-bk-35593) (Bankruptcy Judge G. Michael Halfenger)