The US Supreme Court’s made an important decision regarding the chapter 13 means test in the Lanning case.  This case dealt with issues present in the calculation of the the s “projected disposable income,” which figure forms one of the bases upon which the amount of the debtor’s chapter 13 plan is based.

The main issue presented was the determination of the debtor’s “projected disposable income” was strict determined by the calculation perform on Form B22C or whether a bankruptcy court may take into account for changes in the debtor’s income or expenses that are known or virtually certain at the time of confirmation. This situation is presented when there have substantially changes in the debtor’s income or expenses that would produce a figure different from that determined by the calculation in the Form B22C.

The Supreme Court held that the bankruptcy court may depart from the calculation made on Form B22C and take into account  changes in the debtor’s income or expenses that are known or virtually certain at the time of confirmation.