In re Kuwik

ORDER

JAMES R. SACCA, Bankruptcy Judge.

Although Congress has defined “current monthly income” in 11 U.S.C. § 101(10A) simply as “average monthly income” with a few modifications, this definition begs the *698question: What is income? As simple as this question may sound, answering it can be complicated when dealing with a self-employed debtor. For a wage-earner, income is ordinarily easily determined by reference to pay stubs. But for the self-employed, income could refer to gross income before expenses, or it could refer to net income after business expenses.

For purposes of this case, the…