In a bad-facts-make-bad-law situation, the Southern District of New York affirmed the denial of student loan discharge where the chapter 7 debtor sought to have his religious contributions deducted from his income, and, unfortunately, in so holding, the district court went beyond the bankruptcy court holding to add some unpleasant dicta of its own. In re Lozada, No. 18-11643 (S.D.N.Y. June 12, 2019).
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