In re: Renita Sheri Hall, 12 B 43452, involved a case where a trustee objected to confirmation of a Chapter 13 plan because the debtor was continuing contributions to her 401(k). The trustee’s reasoning in objecting to the plan was that the debtor was not applying all of her projected disposable income to make payments to creditors. The debtor appealed, and the bankruptcy court overruled the objection, saying that money set aside in a 401(k) is not available to the debtor and therefore can’t be consider part of her projected disposable income. Therefore, debtor was applying all of her disposable income for creditors, and the objection to her plan was not justified. Keep in mind that this ruling only applies to 401(k) payment initially made before the petition was filed and continued on after the petition was filed.