In re Sanchez, 394 B.R. 574 (Bankr. D. Colo. 2008) (Brooks) (Rejecting Money v. Kagenveama (In re Kagenveama), 527 F.3d 990 (9th Cir.), amended, 541 F.3d 868 (9th Cir. 2008), Chapter 13 debtors must propose three-year or five-year plan without regard to whether there is any disposable income; projected disposable income is forward-looking concept that is inconsistent with “snapshot” adopted by Ninth Circuit in Kagenveama.). Accord In re Pfeiler, 395 B.R. 464 (Bankr. D. Colo. 2008) (Brooks).

In re Roberts, No. 07-15653DWS, 2008 WL 4279549, at *3 (Bankr. E.D. Pa. Sept. 17, 2008) (Sigmund) (Not necessary to decide whether projected disposable income test is “forward looking” or a mathematical formula because disposable income on Form B22C would be negative even if expense deduction is disallowed for pension loan repayments that will complete during second year after confirmation.).

See Also: Bankruptcy New York