Tanya Johnson v. William Zimmer, 686 F.3d 224

Debtor Tanya Johnson filed a Chapter 13 petition in Sept. 2010; trustee appointed; ex-husband creditor objected to plan.
Parties stipulated: joint custody of two minor sons; no child support; shared expenses; medical expenses split equally; Debtor’s husband has three prior children residing part-time with her.
Debtor’s plan counted seven in household (Debtor, her husband, two biological sons, three stepchildren) though not all resided full-time.
Creditor argued household size should reflect actual economic impact, reducing expenses and increasing disposable income.
Bankruptcy court adopted an “economic unit” approach with fractional memberships for part-time residents (two sons .56 each, three stepchildren .49 each) totaling 2.59, rounded to three, yielding a five-person household (Debtor, husband, and three children).
Court granted leave to amend plan based on a five-person household; interlocutory appeal allowed under 28 U.S.C. § 158(a)(3) and Fed. R. Bankr. P. 8003.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper definition of 'household' for §1325(b) disposable income	Johnson argues for heads-on-beds (Census-based) definition.	Zimmer argues for economic-unit approach with interdependence.	Economic-unit approach affirmed as correct.
Whether part-time members may be fractionalized in calculation	Fractions undermine the statutory text requiring whole individuals.	Fractions reflect real-world economic interdependence.	Fractions permitted; rounding to whole individuals allowed when appropriate.
Relation of household size to means test calculations ( §707(b) and tax-dependent approach )	Would rely on tax-dependent method for consistency with means test.	Economic-unit method better aligns with Code and BAPCPA goals; tax-dependent approach under-inclusive.	Economic-unit approach preferred; tax-dependent not adopted.
Whether Census heads-on-beds conflicts with Code purposes	Census-based definition captures all residents and is fair.	Broad Census definition misaligns with disposable income calculation.	Heads-on-beds rejected; not aligned with Code goals.

Hamilton v. Lanning, 130 S. Ct. 2464 (2010) (describes disposable income and means test framework under §1325)
Ransom v. FIA Card Servs., N.A., 131 S. Ct. 716 (2011) (statutory interpretation of means test; cautions about incorporating IRS guidance)