.jpg)
Evidence required to avoid a lien under 522(f) years
The 522(f) form motion needs to be revised. I personally would not use it.
Sincerely,
*Michael Avanesian, Esq. *
Avanesian Law Firm
101 N. Brand Blvd. PH 1920
Glendale, CA 91203
Tel: 818.276.2477 | Fax: 818.208.4550
*Confidentiality**: *This electronic transmission and its contents are
legally privileged and confidential information and intended solely for the
use of the addressee. If the reader of this message is not the intended
recipient, you are hereby notified that any dissemination, distribution,
copying or other use of this message and its contents is strictly
prohibited. If you have received this transmission in error, please reply
to us immediately and delete this message from your directory.
*IRS Circular 230 Disclosure:* To ensure compliance with requirements
imposed by the IRS, please be advised that any U.S. federal tax advice
contained in this communication (including any attachments) is not intended
or written to be used or relied upon, and cannot be used or relied upon,
for the purpose of (i) avoiding penalties under the Internal Revenue Code,
or (ii) promoting, marketing or recommending to another party any
transaction or matter addressed herein.
On Thu, Oct 22, 2015 at 7:11 AM, Shannon Doyle
sdoyle@ebankruptcyassistants.com [cdcbaa] wrote:
>
>
> I have filed these motions many times with no issues but recently I had
> one wherein Judge Donovans clerk rejected the order avoiding lien because
> the evidence provided in the motion included the value of the home as of
> the date of filing and the first mortgage payoff as of the date of
> filing. The clerk stated the evidence needs to show the first mortgage
> payoff as of the *current date* (which happened to be three years after
> the date of filing) . I followed the clerks instructions and the order
> was entered but this didnt make sense to me. Why do you skew the equity
> analysis in this way using the value from the date of filing and the
> payoff from three years later? Is this just a Judge Donovan thing or am I
> completely missing something here? I have the same fact pattern with Judge
> Kaufman do I use the first mortgage payoff as of the date of filing or as
> of today?
>
>
>
> Thank you!
>
>
>
>
>
> [image: New Professional Pic2]
>
> Shannon A. Doyle
>
> *Attorney | Virtual Bankruptcy Assistant*
>
> *Phone: 855-378-4080 *
>
> *Fax: 562-249-8435 *
>
> [image: PetitionPartnD05bR08aP01ZL-Madison8a]
>
>
> [image: http://pcmweb.net/devglobal/emaildev/eB ... img/fb.png]
> [image:
> http://pcmweb.net/devglobal/emaildev/eB ... witter.png]
> [image:
> http://pcmweb.net/devglobal/emaildev/eB ... google.png]
> [image:
> http://pcmweb.net/devglobal/emaildev/eB ... nkedin.png]
> [image:
> http://pcmweb.net/devglobal/emaildev/eB ... /email.png]
>
>
>
>
>
>
>
>
The 522(f) form motion needs to be revised. I personally would not use it.
The post was migrated from Yahoo.