LAST week we discussed the conversion of a chapter 7 case into chapter 13. Today we discuss converting a chapter 13 case to chapter 7. Many debtors who want chapter 7 relief are not eligible either because they fail the chapter 7 means test, or the liquidation analysis, which shows that they have substantial, that are not exempt. These debtors usually have household incomes that are above the median in California. The means test is an objective way of computing disposable income based on IRS standards. This device has many critics because sometimes the result of its application is ridiculous. For instance, a debtor with several dependents will benefit from its application because debtor can claim the higher IRS allocation for rent even if debtor’s actual rent is lower. If debtor has 4 dependents his means test rent is at least $1,400 monthly. If the rent he actually pays is only $700, he can claim the difference of $700 as additional expense when determining disposable income under the means test. On the other hand, a debtor who is married without dependents who actually pays rent of $2,900 can only deduct the amount of $1,100 for rent under the means test. In this situation, the difference of $1,800 of non deductible expense can knock the chapter 7 case into a chapter 13 unless debtor has more qualifying expenses to offset $1,800 because substantial disposable income may result from the fact that only $1,100 of the $2,900 rent is deductible under the means test.