HOA dues. The parties have stipulated that post-petition HOA dues in this case total $1,666.89. II. Analysis The HOA Declaration in this case is binding on the parties pursuant to Va. Code Ann. § 55-515(A). Than asserts that the post-petition HOA dues should be dischargeable in bankruptcy, while The Association claims that the dues are non-dischargeable debts. Both parties rely on the rationale of the court’s opinion in In re Rivera, 256 B.R. 828 (Bankr. M.D. Fla. 2000). In Rivera, the Bankruptcy Court for the Middle District of Florida held that HOA dues were not dischargeable when they accrued between the time a debtor filed for bankruptcy and when he ceased to be the owner of the lot in question. Id. at 830, 835-36; see also In re Rosenfeld, 23 F.3d 833, 835-36 (4th Cir. 1994) (<HOLDING>). The Rivera court noted that there are three
holding that the payments accrued holding that the district court had bankruptcy jurisdiction over a professional malpractice action filed by a title 11 debtor against the law firm that represented him in his bankruptcy case under section 1334b because the malpractice claim arose in the bankruptcy case holding that housing cooperative dues were not dischargeable when they accrued between the time a debtor filed for bankruptcy and when he gave up record title to the property in question holding that a bankruptcy debtor may claim the homestead exemption for real property transferred to a selfsettled revocable trust even though the settlor and the beneficiary as well as the bankruptcy debtor were the same person holding that bankruptcy court is without jurisdiction to control disposition of chapter 13 debtors property that is not property of the bankruptcy estate unless the property is related to the bankruptcy proceedings of the code