Card Serv./Visa v. Vermillion (In re Vermillion), 136 B.R. 225, 227 (Bankr.W.D.Mo.1992); FCC Nat’l Bank v. Bartlett (In re Bartlett), 128 B.R. 775, 779-80 (Bankr.W.D.Mo.1991). But see AT&T Universal Card Serv. Corp v. Nguyen (In re Nguyen), 208 B.R. 258, 261 (D.Mass.1997) (stating that "an intent to deceive cannot be inferred solely from a failure to perform an implied promise, ... [and] the inability to repay a debt at the time it is incurred ... is insufficient as a rule to prove fraud”). 43 . Feld, 203 B.R. at 367; AT&T Universal Card Serv. v. Alvi (In re Alvi), 191 B.R. 724, 732-33 (Bankr.N.D.Ill.1996). 44 . 196 B.R. at 449. 45 . Feld, at 365. 46 . Id. 47 . Id. 48 . GM Card v. Cox (In re Cox), 182 B.R. 626, 628 (Bankr.D.Mass.199 chards), 196 B.R. 481, 482 (Bankr.E.D.Ark.1996) (<HOLDING>). But see AT&T Universal Card Serv. v. Burdge
holding that medical expenses must be proven to be both reasonable and necessary holding that release status must be proven by clear and convincing evidence through reliable documentary evidence holding that reliance is not an element to be proven under securities fraud in indiana holding all exceptions to discharge under  523a must be proven by a preponderance of the evidence holding that reliance must be proven by some evidence