9th Circuit BAP Rules that Bankruptcy Court may Consider Postpetition Events as Part of the Totality of the Circumstances

In re Ng may be accessed here.  The Debtor’s income increased after he filed.  The BAP says that the bankruptcy court may condsider that as part of the totality of the circumstances when deciding whether to dismiss a chapter 7 under section 707(b)(3).  By the way, the lower court also ruled that a debtor may deduct mortgage payments on the means test, even if he intends to surrender or abandon the home.  Since that ruling was irrelevant, the BAP did not discuss it.