Law360, New York ( February 16, 2016, 5:30 PM EST) -- A Chapter 11 debtor's impairment in its reorganization plan of two unsecured claims filed by its former lawyer and accountant "was transparently an artifice to circumvent the purposes of" the Bankruptcy Code, held the U.S. Court of Appeals for the Sixth Circuit on Jan. 27, 2016. In re Village Green I GP, 2016 U.S. App. LEXIS 1243, at *2 (6th Cir. Jan. 27, 2016). Affirming the reversal of the bankruptcy court's finding that the debtor had "proposed its plan in good faith," the Sixth Circuit rejected the debtor's "assertion that it could not safely pay off the [two] minor claims (total value: less than $2,400) up front rather than over 60 days." It stressed the debtor's projected "net income of $71,400 per month" to support the "feasibility" of its plan, which undermined its purported need to "ration ... every dollar." Id. at *5....