Section 523 of the Bankruptcy Reform Act' lists ten categories of
debts which are excepted from discharge.2 The standard of proof necessary
to establish the nondischargeability3 of debts under this section
was until recently unclear.
"Exceptions to Discharge: The Supreme Court Adopts A Preponderance of the Evidence Standard of Proof in Section 523 Proceedings,"
Nova Law Review: Vol. 15
, Article 16.
Available at: http://nsuworks.nova.edu/nlr/vol15/iss3/16