In re Feagan, 549 B.R. 811

Debtor Bruce Keith Feagan is an above-median Chapter 13 debtor whose plan does not pay unsecured claims in full; Trustee objected, triggering the projected disposable income (PDI) test under 11 U.S.C. § 1325(b).
Feagan claimed the IRS Local Standards "Ownership Costs" transportation allowance ($517) to reduce his monthly PDI; his car is encumbered by a title-pawn (nonpurchase-money) obligation with a required monthly payment of $51.43.
Under the means test mechanics, Feagan’s Ownership Costs deduction must be reduced by his actual secured-car payment, yielding a net Ownership Costs deduction of $465.57 and a monthly PDI of $153.63; his plan pays unsecureds $9,250 over 60 months.
Trustee argued the Ownership Costs deduction applies only to purchase-money loans or leases, so Feagan should not be allowed the deduction for a title pawn, which would substantially increase required unsecured distributions.
The court analyzed Supreme Court precedent (Ransom v. FIA) and IRS Collection Financial Standards and concluded the Ownership Costs deduction applies to vehicle-encumbrance payments regardless of whether the debt is purchase-money.

Issue	Feagan's Argument	Trustee's Argument	Held
Whether an above‑median Chapter 13 debtor may claim the IRS "Ownership Costs" deduction for a vehicle encumbered by a nonpurchase‑money obligation	Ownership Costs deduction applies because debtor must make payments to retain vehicle, so the category is "applicable"	Ownership Costs limited to loan or lease payments that financed purchase or lease; title‑pawn is not purchase‑money	Allowed: Ownership Costs deduction applies to nonpurchase‑money encumbrances; Trustee's objection overruled

Ransom v. FIA Card Servs., N.A., 562 U.S. 61 (2011) (interprets "applicable" means debtor must incur expense in category; holds ownership category covers loan or lease payments)