Sawyer v. Budrow (In Re Budrow)
Mona Y. Sawyer filed an adversary proceeding against Mr. and Mrs. Budrow, seeking to except a $72,000 debt from discharge or to deny their general discharge under Chapter 7 of the Bankruptcy Code. The debtors, appearing pro se, were found to have committed multiple violations. These included intentionally omitting numerous creditors, including the IRS, operating a business and collecting receivables without authorization post-petition, failing to maintain adequate financial records for their businesses and personal affairs, and making false oaths in their bankruptcy petition regarding assets and income. The Court determined that the debtors engaged in a knowing scheme to conceal substantial income and assets through alleged family trusts. Consequently, the Court denied the debtors' general discharge based on multiple grounds under § 727(a) of the Bankruptcy Code.