Reopening Closed Cases with Subsequent Income Tax Refunds.
U.S. Bankruptcy Court for the District of Montana
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Trustee shall not need to file motions or take any other affirmative actions to reserve the right to reopen closed cases in which the only asset trustee may later seek to administer upon reopening is a tax refund based upon income earned before the commencement of the case that debtor receives. Related Authority: 11 U.S.C. §§ 521(1) and 554(c)