Massachusetts Bankruptcy Court Holds Means Test Form Not Due on Conversion

Courts have divided on whether a new means test form is due upon conversion from Chapter 13 to Chapter 7. Most recently, Massachusetts bankruptcy Judge Rosenthal held that a new form is not due upon conversion. See In re Guarin, 2009 WL 4500476 (Bkrtcy.D.Mass. 2009). In this, he split with colleagues in this circuit, notably the Rhode Island Bankruptcy Court, which required an new means test in the case of In re Perfetto, 361 B.R. 27 (D. R.I.2007).