Case Summary:
Chapter 12 Trustee filed a motion to dismiss the Debtors’ case due to the Debtors’ insufficient income from farming operations to satisfy Chapter 12 eligibility requirements. Debtors’ gross farm income in 2019 was $47,650. Their farm income has two components: (1) cattle sales and breeding ($14,650), and horse boarding ($33,000). While recognizing the recent evolutions of farming and the agriculture industry, the Court determined the Debtors’ horse boarding operation was not a farming operation because the Debtors did not bear the risks traditionally associated with farming activity. Debtors did not raise the horses or sell them. They simply boarded horses for other individuals and took care of neglected horses through their non-profit entity that is funded through donations and fundraising events. Debtors’ 2019 farm income was insufficient to meet the Chapter 12 eligibility requirements. Debtors’ case was dismissed.

Statute/Rule References:
11 U.S.C. § 101(18) -- Definition of Family Farmer
11 U.S.C. § 101(21) -- Definition of Farming Operation
11 U.S.C. § 109(f) -- Chapter 12 Eligibility

Key Terms:
Custom Framing
Farming Operation
Horse Boading