435, 442 (Bankr.E.D.Tenn.2001), Johnston v. Henson (In re Henson), 197 B.R. 299, 302-303 (Bankr.E.D.Ark.1996), and Schmitt v. Eubanks (In re Schmitt), 197 B.R. 312, 316 (Bankr.W.D.Ark.1996), with McKinnis v. McKinnis (In re McKinnis), 287 B.R. 245, 257 (Bankr.E.D.Mo.2002), McCracken v. LaRue (In re LaRue), 204 B.R. 531, 535-536 (Bankr.E.D.Tenn.1997), Belcher v. Owens (In re Owens), 191 B.R. 669, 674 (Bankr.E.D.Ky.1996), Barstow v. Finaly (In re Finaly), 190 B.R. 312, 315 (Bankr.S.D.Ohio 1995), and Stegall v. Stegall (In re Stegall), 188 B.R. 597, 598 (Bankr.W.D.Mo.1995). 1. Section 52 F.3d 192, 200 (observing that “Congress amended the Bankruptcy Code in 1994 to allow exemptions from discharge for all obligations incurred as a result of a divorce decree”); Osborne, 262 B.R. at 445 (<HOLDING>); Salerno v. Crawford (In re Crawford), 236
holding that pay on death accounts were not part of the bankruptcy estate under  541 because under kansas law debtor had no property interest in the accounts until the death of the owner holding that debtors liability for payment of the balance owing on three joint credit card accounts assumed by the debtor under a marital dissolution agreement with his former spouse were nondischargeable under  523a15 holding nondischargeable a debtors obligation to his former spouse under a divorce decree to assume liability for two joint debts to a third party and stating that  523a15 is intended to cover divorcerelated debts such as those in property settlement agreements holding arbitration clause in credit card agreement unconscionable holding that a cause of action exists under  523a15 by which a debtors own former divorce attorneys might except from discharge the debtors contractual obligation to them