to the ICRP in the undue hardship analysis. First, tax liability is not certain to flow from the discharge of the remaining debt at the end of the 25-year period. 26 U.S.C. § 108(a)(1)(B) excludes from gross income “any amount which (but for this subsection) would be includible in gross income by reason of the discharge (in whole or in part) of indebtedness of the taxpayer if the discharge occurs when the taxpayer is insolvent,” provided that, under § 108(a)(3), “the amount excluded under paragraph (1)(B) shall not exceed the amount by which the taxpayer is insolvent.” For the “purposes of [section 108], the term ‘insolvent’ means the excess of liabilities o the relatively lenient terms of the ICRP would impose, or contribute to creating, an undue hard ship. See Lee, 352 B.R. at 96 (<HOLDING>). There may also be circumstances in which a
holding that a debtors ability to make reduced payments under the icrp is relevant to the inquiry of whether the debtors reasonable future financial resources will cover payment of the debt while still allowing a minimal standard of living holding even minimal payment required by the icrp could be beyond the debtors means holding that a debtors expenses were not minimal because they included a hairdresser chiropractor and 544 car payment holding sophisticated means and the nowdefunct more than minimal planning enhancements could be applied cumulatively holding sophisticated means and the now defunct more than minimal planning enhancements could be applied cumulatively