But a similar factual inquiry into the parties’ intent does not occur when the bankruptcy court interprets a state court’s ruling awarding fees in post-decree litigation over custody or visitation. Thus, characterization of this issue as one of fact is questionable. It is an issue of federal law, to be determined with reference to state law. Therefore, I did not find Adams v. Zentz persuasive. Other courts have used different reasoning in reaching the Adams result. Some courts, like the bankruptcy court below, have focused solely on whether the attorney fees were awarded based on financial need. See, e.g., Fitzpatrick v. Schlitz (In re Schlitz), 97 B.R. 671, 674 (Bankr.N.D.Ga.1986); cf. Seymour Ostrow, P.C. v. Schwartz (In re Schwartz), 53 B.R. 407, 411 (Bankr.S.D.N.Y.1985) (<HOLDING>). Others have held that attorney fees incurred
holding punitive damages nondischargeable under  523a6 when such damages are based on the same conduct as the underlying nondischargeable judgment holding that in a chapter 7 case postpetition interest on a nondischargeable tax claim is also nondischargeable holding nondischargeable postpetition interest on debt that was determined to be nondischargeable under section 523a2 as obtained by fraud holding fee awarding nondischargeable because former spouse was impoverished holding that attorneys fees were nondischargeable as maintenance even though award was in favor of attorneys not spouse because it was rendered in light of the financial resources of the parties