From Aki Koyama, Staff Attorney for a Chapter 13 Trustee here in Los Angeles:
Judge Klein announced in court last Wednesday that she will not be following Judge Yun’s Memorandum Opinion In re Carolyn Deutsch (6:14-bk-21126) which is about disallowing contribution income if there is insufficient evidence of a basis for the contribution income. Among other factors, the opinion requires a history of contributions prior to the filing of the case. I have been told that Judge Zurzolo has also indicated he will not be following this opinion.