Local Rule RULE 5010-1: Reopening Closed Cases with Subsequent Income Tax Refunds.
Bankr. D. Mont. — General rule
RULE 5010-1. Reopening Closed Cases with Subsequent Income Tax Refunds.
Trustee shall not need to file motions or take any other affirmative actions to reserve the right to reopen closed cases in which the only asset trustee may later seek to administer upon reopening is a tax refund based upon income earned before the commencement of the case that debtor receives.
Related Authority: 11 U.S.C. §§ 521(1) and 554(c)