US Bankruptcy Court EDTN Docket Feed

Selcuk Ahmet Tombul v. US Trustee - Subchapter V Eligibility

The U.S. Bankruptcy Court for the Eastern District of Tennessee sustained the United States trustee's objection to Selcuk Ahmet Tombul's election to proceed under Subchapter V of Chapter 11, finding the debtor was not engaged in commercial or business activities on the petition date. The debtor, a cardiologist whose income derives entirely from W-2 wages after his medical practice (Chattanooga Heart and Rhythm Center PLLC) ceased operations, failed to satisfy the statutory requirement. The court held that merely owning a dormant business and addressing personal liability for guaranteed business debts does not constitute engaging in commercial or business activities.

Trustee Objects to $11,000 Retirement Benefit Exemption in Chapter 7 Case

Ann Mostoller, Chapter 7 Trustee, objected to Debtor Kaitlin Nicole Williams' claimed exemption of $11,000.00 from her former spouse's 401(k) retirement benefits under T.C.A. § 26-2-111(1)(D). The Bankruptcy Court analyzed the Final Decree of Divorce (April 1, 2024), the Qualified Domestic Relations Order entered by Sevier County Chancery Court (January 3, 2025), and the QDRO approval letter from the UPS 401(k) Administrative Committee (January 15, 2025) to determine whether the Retirement Benefit constitutes property of the estate. The determinative issue is whether the $11,000 award survives as property of the estate under 11 U.S.C. § 541 given the timing of the QDRO relative to the bankruptcy filing. The court identified this as a core proceeding under 28 U.S.C. § 157(b)(2)(A), (B), and (O).

Peggy C Manis — Reverse Mortgage Rule 3002.1 Notice Requirements Ruling

The United States Bankruptcy Court for the Eastern District of Tennessee ruled on March 24, 2026, that holders of claims secured by reverse mortgages on debtors' principal residences were required to comply with Federal Rule of Bankruptcy Procedure 3002.1's notice requirements prior to a recent amendment to the rule. The court held that the claim holder was obligated to timely file and serve notices itemizing all fees, expenses, and charges incurred during the Chapter 13 bankruptcy case. Because the claim holder failed to comply with Rule 3002.1, the court prohibited the claim holder and its successors, transferees, and assigns from ever using nonpayment of those fees, expenses, or charges as a basis for declaring a default or foreclosing on the debtor's residence.