The Court ruled in Ransom, primarily in reliance on supplemental commentary authored by the IRS, that a car-ownership cost allowance was available only to debtors who made loan or lease payments on a vehicle.
[3] This replaced the prior practice of bankruptcy courts having to make case-by-case determinations of a debtor's expenses to calculate available income.
The Collection Financial Standards explained that "Ownership Costs" represented "nationwide figures for monthly loan or lease payments," "base[d] .
"[6] Jason M. Ransom filed for Chapter 13 bankruptcy in July 2006 and itemized over $82,500 in unsecured credit card debt, including nearly $33,000 held by MBNA (later FIA).
[6][7] In his proposed five-year repayment plan, Ransom claimed the "Ownership Costs" allowance, fixed at the time at $471 per month for one car, for his 2004 Toyota Camry which he owned outright.
[8] MBNA objected on the basis that Ransom did not make loan or lease payments on the car and thus was not entitled to that cost allowance.
[14] Justice Antonin Scalia, known for his strict textualist jurisprudence, criticized the petitioner for not including in his appellate brief the statutory language that was at issue.
[14] Chief Justice John G. Roberts suggested that there was no good answer to the issue in the case, characterizing the parties' arguments as leading to equally "absurd" results.
"[15] Finally, the Court viewed its interpretation as in furtherance of the objectives of BAPCPA, which was to ensure that debtors pay creditors the maximum amount they can afford.
[17] To resolve the question of what kind of expense the "Ownership Costs" allowance covered, the Court turned to the Collection Financial Standards (CFS).
Though the statute did not incorporate the CFS, the Court thought that, given that the National and Local Standards are created, revised, and applied by the IRS, "[t]he agency might, therefore, have something insightful and persuasive (albeit not controlling) to say about them.
Regarding the "Ownership Costs" table, the CFS explained that the dollar amounts derived from a five-year average of car financing data compiled by the Federal Reserve Board.
Justice Antonin Scalia, in dissent, stated he would have held that a debtor who owns a car free and clear is still entitled to the car-ownership allowance.
'"[23] Though the Court seemed most concerned that a debtor without actual ownership costs would nevertheless be able to withhold income from repayment on that basis, Scalia believed that such an overallowance was inevitable with a standardized formula like the means test.