US Bankruptcy Court EDMO Docket Feed

Barnett, Parson et al. Chapter 12 Farm Bankruptcy Memorandum Opinion

The United States Bankruptcy Court for the Eastern District of Missouri issued a memorandum opinion consolidating four Chapter 12 farm bankruptcy cases (Barnett, Parson, Hayes, Walker) in which the United States, as unsecured creditor, objected to the debtors' plans of adjustment on three common grounds. The court addressed issues involving Section 1232 de-prioritized tax treatment in liquidation analyses (presenting a question of first impression), whether the disposable-income test requires guaranteed annual payments versus retrospective calculations, and the deductibility of attorneys' and trustee fees from disposable income. The opinion provides interpretive guidance under Sections 1225 and 1232 of the Bankruptcy Code applicable to family farmer Chapter 12 plans in the Eastern District of Missouri.

Chapter 12 Plans: Section 1232 Tax Treatment, Disposable Income, and Fee Deductions

The U.S. Bankruptcy Court for the Eastern District of Missouri issued a memorandum opinion addressing three common objections raised by the United States to multiple Chapter 12 plans of adjustment. The court analyzed how debtors must calculate liquidation analyses for Section 1232 de-prioritized taxes, whether the disposable-income test requires guaranteed annual payments versus retrospective payments, and whether attorneys' and trustee fees may be deducted from disposable income calculations. The opinion involves four Chapter 12 cases: In re Barry Vernon Barnett and Cortney Baugh Barnett (Case No. 25-10071), In re Travis Parson and Casey Parson (Case No. 25-10188), In re Dennis Hayes (Case No. 25-10218), and In re Steven Walker and Keisha Walker (Case No. 25-10430).

Barnett & Parson Chapter 12 Bankruptcy Memorandum Opinion

The U.S. Bankruptcy Court for the Eastern District of Missouri issued a Memorandum Opinion on March 19, 2026 resolving three common issues in four Chapter 12 family-farm bankruptcy cases (Barnett, Parson, Hayes, Walker) where the United States objected to plan confirmation. The Court addressed how de-prioritized taxes under Section 1232 must be treated in liquidation analyses, whether the disposable-income test requires guaranteed payments versus retrospective actual-income payments, and whether attorneys' and trustee fees may be deducted from disposable income calculations. The Court found against the debtors on all three issues.