In re Binesh

542 B.R. 1, 2015 WL 8294929, 2015 Bankr. LEXIS 4156
CourtUnited States Bankruptcy Court, C.D. California
DecidedDecember 8, 2015
DocketCase No.: 8:12-bk-20432-MW
StatusPublished

This text of 542 B.R. 1 (In re Binesh) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Binesh, 542 B.R. 1, 2015 WL 8294929, 2015 Bankr. LEXIS 4156 (Cal. 2015).

Opinion

MEMORANDUM DECISION

WALLACE, United States Bankruptcy Judge

This matter comes before the Court on the motion of chapter 7 trustee Thomas H. Casey (the “Trustee”) to compel the turn[2]*2over of estate property (the “Turnover Motion”). The Court has jurisdiction over this proceeding pursuant to 28 U.S.C. § 1334 and General Order 13-05, filed July 1, 2013, of the United States District Court for the Central District of California. This is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (B) and (E).

The Court held an evidentiary hearing on the Turnover Motion on November 16, 2015. This Memorandum Decision constitutes the Court’s findings of fact and conclusions of law as required in contested matters by Federal Rules of Bankruptcy Procedure 7052 and 9014(c).

Farshid David Binesh and Mojgan Yousefi, husband and wife (the “Debtors”), filed a voluntary petition under chapter 7 of the Bankruptcy Code on August 31, 2012. Debtors scheduled an interest in real property located at 30 Via Silla, Ran-cho Santa Margarita, California (the “Residence”) and subsequently claimed a $100,000 homestead exemption in the Residence on February 21, 2014 on an amended Schedule C form.

The Trustee sold the Residence on September 11, 2014 and distributed $74,682.23 in exempt proceeds to Debtors on September 24, 2014. California Code of Civil Procedure section 704.720(b) provides that if a homestead is sold and proceeds are received in respect of such sale, “[t]he proceeds are exempt for a period of six months after the time the proceeds are actually received by the judgment debtor ... ”■ Section 704.720(b) dovetails with California Code of Civil Procedure section 704.710(c), which defines a “[hjomestead” to include a dwelling acquired by judgment debtors “[wjhere exempt proceeds from the sale ... of a homestead are used toward the acquisition of a dwelling within the six-month period provided by Section 704.720.” Also noteworthy in this regard is the requirement of section 704.710(c) that the dwelling so acquired “... is the principal dwelling in which the judgment debtor or the judgment debtor’s spouse resided continuously from the date of acquisition until the date of the court determination that the dwelling is a homestead..."

Immediately following the end of the six-month period referenced above — on March 25, 2015 — the Trustee sent Debtors a letter asking them to provide evidence that they timely reinvested the homestead exemption proceeds of $74,682.23 in another residential purchase. The Court’s docket shows that at this point in time the Debtors were self-represented (i.e!, pro se), the services of Charles W. Daff, Esq. as their counsel having terminated a little over one year earlier, on March 19, 2014.

There then followed an exchange of emails and other correspondence between the Trustee and the Debtors. The Debtors claimed to have signed a contract for the purchase of residential real estate located at Imam Reza Boulevard 7th Imam Reza Part 111 North Second Floor in Tehran, Iran (the “Replacement Property”) at a purchase price of 910 million Iranian rials on February 4, 2015. (The contract document is in Farsi and had to be translated into English). By Debtors’ account, the contract for sale provided for a payment of 300 million rials on February 4, 2015, 450 million rials on May 6, 2015 and 160 million rials upon delivery of the Replacement Property. The original closing date for the Replacement Property’s purchase and sale was July 6, 2015.

910 million Iranian rials is worth approximately $30,000 to $35,000. Debtors have freely admitted that they used a large portion of the $74,682.23 of exempt proceeds for rent, food and other living expenses.

[3]*3Ms. Yousefi traveled to Iran in April 2015 to help facilitate the Replacement Property’s acquisition. Initially, the Replacement Property was not ready for oc- ■ cupancy because of pending construction but became ready for occupancy between August 2015 and the date of the evidentia-ry hearing.

As of the date of the evidentiary hearing in mid-November 2015, escrow has not yet closed, Debtors still do not hold title to the Replacement Property and still have not occupied it (and have never occupied it). Their intention is to travel to Iran when this bankruptcy case is concluded and to occupy the Replacement Property as their principal (and perhaps only) residence. As of the date of the evidentiary hearing, Debtors resided in Foothill Ranch, California.

If a judgment debtor receives exempt proceeds from the sale of a homestead and, within six months, pays the full amount of the exempt proceeds “toward the acquisition of a dwelling,” California Code of Civil Procedure § 704.710(c), the exemption is not lost and instead carries over to the replacement dwelling/homestead provided that the judgment debtor acquires the replacement dwelling/homestead within the six-month period and resides continuously in it from the date of its acquisition until the date of the court determination that the dwelling is a homestead.

New construction of a replacement dwelling/homestead,1 however, can complicate the issue.. Consider a case where a judgment debtor receives $100,000 in exempt proceeds on July 1, 2015 and uses the full $100,000 on September 30, 2015 to buy a house that is then under construction and is projected to be complete and ready for occupancy on December 15, 2015. If the replacement dwelling/homestead is in fact completed on December 15, 2015, and the judgment debtor moves in on that date and remains using it as his or her principal residence through the date of the court determination, the exemption should attach to the replacement dwelling/homestead. An objection ' that the judgment debtor should lose the exemption because of a failure to move in on a purported “date of acquisition” of September 30, 2015 ought to be overruled on the ground that the “dwelling” was not actually acquired until December 15, 2015 — because a dwelling is a “house together with ... the land upon which [it is] situated,” California • Code of Civil Procedure § 704.710(a)(1), and a reasonable interpretation of “house” is a house ready for occupancy, not a partially completed structure that may lack a roof, plumbing and electricity.

But suppose that in the foregoing illustration the projection is missed and the replacement dwelling/homestead does not become ready for occupancy until January 31, 2016 (and that the judgment debtor moves in on that date). Is the exemption lost? Arguably it is, because of the provision in California Code of Civil Procedure section 704.720(b) that “[t]he proceeds are exempt for a period of six months after the time the proceeds are actually received by the judgment debtor, except that, if a homestead exemption is applied to other property of the judgment debtor ... the proceeds thereafter are not exempt.” A not unreasonable interpretation of this provision is that it places a hard-and-fast temporal limitation of six months on the transmutation of the cash exempt proceeds [4]

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Related

Barnhart v. Thomas
540 U.S. 20 (Supreme Court, 2003)
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Cite This Page — Counsel Stack

Bluebook (online)
542 B.R. 1, 2015 WL 8294929, 2015 Bankr. LEXIS 4156, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-binesh-cacb-2015.