Yes, in a recent New York decision, the court ruled that under the plain meaning of the Bankruptcy Code, a debtor in a one-person household who actually incurs operating expenses for two motor vehicles may claim a deduction in the means test for operating expenses for two vehicles, even though the Internal Revenue Service manual specifically states that “a single taxpayer is normally allowed ownership and operating costs for one vehicle.”
In re Addison, 580 B.R. 24 (Bankr. E.D. N.Y., Jan. 11, 2018)