In re Williams, 394 B.R. 550 (Bankr. D. Colo. 2008) (Brown) (Attempting to harmonize Money v. Kagenveama (In re Kagenveama), 527 F.3d 990 (9th Cir.), as amended, 541 F.3d 868 (9th Cir. 2008), and In re tanning, 380 B.R. 17 (B.A.P. 10th 2007), appeal docketed, No. 08-3009 (10th Cir. Jan. 14, 2008), disposable income for debtor with CMI greater than applicable median family income is determined consistent with Form B22C and then projected mathematically over applicable commitment period but debtor (only) can demonstrate special circumstances to depart from income or expense calculation on Form B22C).

In re Hedge, 394 B.R. 463 (Bankr. S.D. Ind. 2008) (Lorch) (Citing Money v. Kagenveama (In re Kagenveama), 541 F.3d 868 (9th Cir. 2008), projected disposable income is disposable income as defined in § 1325(b)(2) “projected” over life of plan.).
In re Minahan, 394 B.R. 116 (Bankr. W.D. Va. 2008) (Stone) (FollowingIn reJass, 340 B.R. 411 (Bankr. D. Utah 2006), projected disposable income is determined as of “effective date of the plan” which requires consideration of changes in income and expenses between the petition and confirmation.).

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