Recovery of tithes held not to be substantial burden

Tue Apr 21 19:45:57 PDT 1998

    In re Gomes, 1998 WL 167276 (Bankr. D. Or. Apr. 7), holds that
recovery of tithes contributed by a debtor isn't a substantial burden
on either the debtor's or the church's exercise of religion.  "The
Trustee's efforts to avoid the Transfers have neither restricted the
Gomes in their prepetition or postpetition tithing practices nor done
anything to shake the Gomes' belief that they should tithe."

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Eugene Volokh, UCLA Law School, (310) 206-3926  fax -7010
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