Applying the “forward-looking approach” embraced in Ransom v. FIA Card Services, N.A., 131 S.Ct. 716 (2011) and Hamilton v. Lanning, 130 S.Ct. 2464 (2010), even though those were Chapter 13 cases, two courts held that a Chapter 7 debtor may not deduct, in the means test, payments on secured debt for which the debtor intends to surrender the collateral.
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