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 BOOK FEATURED ON THIS PAGE

King's Guide To Practice Under BAPCPA
The Bankruptcy Reform Act of 2005
With CD Library

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ABOUT THE AUTHOR

TABLE OF CONTENTS

WHAT THEY'RE SAYING

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KING BANKRUPTCY PRACTICE SERIES
RELEASE 2009 # 2 SKU 101-A

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KING'S GUIDE TO PRACTICE
UNDER THE
BANKRUPTCY REFORM ACT OF 2005

For a similar product that is available see

King's Fundamentals of Consumer Bankruptcy
Law & Practice

 

 

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ABOUT THIS BOOK

Published By
KING BANKRUPTCY PRACTICE
Edition 2009

NOTE: This book is intended for lawyers who already have a basic working familiarity with consumer bankruptcy law. Additional books are planned for the inexperienced professional, and these should be out in early 2006.

THE ROADMAP TO BAPCPA

586 pages

For the experienced consumer bankruptcy lawyer
5th revised & enlarged release / Comb binding / with CD and appendix / Now in stock.
Includes: 9 Flow-charts / 15 Checklists / 6 Model Disclosure Statements / + Calculators
& Full text of the Bankruptcy Reform Act /

The extensive and bewildering changes to the Bankruptcy Code rendered by the Reform Act are organized, sorted out, prioritized and simplified for the consumer bankruptcy attorney. Morgan King focuses on the sections that are directly relevant to daily practice. The accompanying CD contains the full text of the Reform Act, the 500-page House Judiciary Committee Report, the IRS Financial Collection Standards, and other useful reference material.

THE KING BANKRUPTCY PRACTICE SERIES

THE ESSENTIAL DESKBOOK FOR
THE EXPERIENCED PROFESSIONAL

BOOK & CD

$189.95 +s&h 20.80

Updated as of April 2009
Comes with King's library on CD containing:
Complete text of The Guide
Complete Text of the Reform Act
Other useful resources - see info below

This book covers all aspects of the Reform Act - not just tax discharge: For the book on Discharging Taxes click here
CONTRIBUTORS

A number of lawyers have graciously devoted their time, advice and document contributions to The Guide. Among these are:

  • Wayne R. Bodow
  • O. Max Gardner
  • Norma Hammes
  • James Gold
  • Charles R. Tropp
  • Jay S. Fleischman
  • William Weber
  • Howard Goldstein
  • George C. Heck
  • Michael J. Primus
  • Marylin G. Miller
  • Denice Patrick
  • Paul Stewart Snyder
  • Thomas J. Yerbich
  • Adam G. Schachter
  • David Andersen
  • Andrew Temin
  • Gary Holt
  • Edward Doney
  • Edward Laughlin
  • Richard Cartwright
  • Kevin Chern
  • Brett Weiss
  • David Reichel
  • Kathy Cruz
  • Carmen Dellutri
  • John Lang
  • David Sergi

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KING'S GUIDE TO PRACTICE

TABLE OF CONTENTS

STEP 1

ROADMAP TO HANDLING A CONSUMER CASE

  • 1.1 Know the key changes
  • 1.2 The roadmap
  • 1.3 Preparing the office
  • 1.4 The probing client interview
  • 1.5 The credit briefing
  • 1.6 The median income and means tests
  • 1.7 Changes in exemptions and discharge of debts
  • 1.8 Selecting the chapter & commencing the case
  • 1.9 The meeting of creditors
  • 1.10 Post-petition issues & tasks
  • 1.11 Proceed to Step 3

STEP 2

OVERVIEW & SUMMARY OF KEY PROVISIONS

  • 2.1 Overview
  • 2.2 Background & legislative intent
  • 2.3 Step-by-step roadmap
  • 2.4  Review of key provisions
  • 2.5 Lawyers held to greater accountability
  • 2.6 Lawyers must state they are debt relief agencies
  • 2.7 Filing fee changes
  • 2.8 Written fee agreement required
  • 2.9 New disclosures & instructions to client required
  • 2.10 Audits of schedules, etc.
  • 2.11 Credit briefing required
  • 2.12 Proof of income and calculation of income required
  • 2.13 New notice provisions
  • 2.14 Names of debtors' children not disclosed
  • 2.15 Time between bankruptcy filings is extended
  • 2.16 Chapter “20” is restricted
  • 2.17 Median income and means tests: presumption of abuse
  • 2.18 Must provide trustee & any party in interest the most recent tax return filed
  • 2.19 Exemptions and exclusions
  • 2.20 Value of collateral is retail value for like condition
  • 2.21 Assumption or rejection of leases & executory contracts
  • 2.22 Preference payments in ordinary course of business
  • 2.23 Tax returns must be filed by 7 & 13 debtors
  • 2.24 Lookback period for fraudulent transfers extended
  • 2.25 Transfers to trusts avoidable
  • 2.26 Automatic stay restricted or terminated
  • 2.27 Financial management course required for discharge
  • 2.28 Dismissal for failure to file documents
  • 2.29 Budget guidelines based on irs expense standards
  • 2.30 Collateral lost for failure to reaffirm or redeem
  • 2.31 Chapter 7 trustees' fees
  • 2.32 Forced conversion to chapter 13 under § 707(b)
  • 2.33 Dismissal of chapter 7 for certain crimes
  • 2.34 Discharge of some debts restricted
  • 2.35 Abuse presumed if income exceeds allowable IRS and code §707(b) expenses
  • 2.36 Preferential transfers
  • 2.37 Additional filings required for chapter 13 debtors
  • 2.38 Cramdown of vehicle & other personal property in chapter 13 is restricted
  • 2.39 Child and spousal support raised to higher priority
  • 2.40 Conversion or dismissal if domestic support not paid
  • 2.41 Chapter 13 super-discharge is restricted
  • 2.42 Changes affecting discharge of taxes
  • 2.43 Charitable or religions contributions
  • 2.44 Mandatory chapter 13 must be for 5 years
  • 2.45 Creditor retains lien until chapter 13 plan completed
  • 2.46 Adequate protection payments in chapter 13
  • 2.47 Interest on non-dischargeable debts in chapter 13
  • 2.48 Effect of conversion from chapter 13 to 7
  • 2.49 Additional hearing required for chapter 13 discharge
  • 2.50 A study of credit practices
  • 2.51 Petition preparers held to greater accountability
  • 2.52 Effective dates
  • 2.53 New official rules and forms
  • 2.54 Proceed to step 2

STEP 3       

PREPARING THE PRACTICE

  • 3.1 Preparation for handling cases
  • 3.2 The written fee agreement
  • 3.3 Obtaining state income data
  • 3.4 Obtaining the IRS expense standards
  • 3.5 Securing the creditors's filed addresses for notice
  • 3.6 Preparing disclosures required in advertising
  • 3.7 Preparing written disclosures to client
  • 3.8 Preparing written instructions to client
  • 3.9 Preparing forms or documents to file with petition
  • 3.10 Prepare a pro-forma annual financial statement
  • 3.11 Revising your in-office forms and checklists
  • 3.12 Prepare new checklists
  • 3.13 Secure copies of IRS forms
  • 3.14 Prepare to conduct probing inquiry
  • 3.15 Consider new software applications to calculate the budget, etc.
  • 3.16 Proceed to Step 4.

STEP 4

THE CLIENT INTERVIEW

  • 4.1 In general
  • 4.2 Who should conduct the interview?
  • 4.3 Using forms and checklist
  • 4.4 Key steps in handling a new case
  • 4.5 Is client an “assisted person”?
  • 4.6 Conduct a probing interview
  • 4.7 Provide written disclosures and instructions
  • 4.8 Identify needed documentation
  • 4.9 Explain the debtor's postpetition duties in bankruptcy
  • 4.10 After the interview
  • 4.11 Do the median income and means tests arithmetic
  • 4.12 Conduct an inquiry to verify the information provided
  • 4.13 Proceed to Step 5 - The Credit Briefing

STEP 5

THE CREDIT BRIEFING

  • 5.1 Credit briefing required before filing
  • 5.2 The purpose of the credit briefing
  • 5.3 Nature of the credit briefing
  • 5.4 Debtor may be exempt
  • 5.5 Court clerk will maintain list of approved agencies
  • 5.6 Filing the certificate and payment plan
  • 5.7 Content of certificate of exigent circumstances
  • 5.8 Cannot require fee
  • 5.9 Cannot report to a credit reporting agency
  • 5.10 Creditor sanctioned for refusal to cooperate
  • 5.11 Payments not avoidable as preference
  • 5.12 Qualifications for credit counseling agencies

STEP 6

CONDUCTING THE MEDIAN & MEANS TESTS

  • 6.1 The means test in a nutshell
  • 6.2 Restricted to consumer debt cases
  • 6.3 The median income test
  • 6.4 The means test
  • 6.5 Figuring disposable income
  • 6.6 Flow-chart aides
  • 6.7 Applying the results
  • 6.8 Dismissal or conversion to chapter 13

STEP 7

EXEMPTIONS & DISCHARGE OF DEBTS

  • 7.1 In general
  • 7.2 Exemptions
  • 7.3 Discharge of debts
  • 7.4 Chapter 13 super-discharge is restricted
  • 7.5 Changes affecting discharge of taxes

STEP 8

SELECTING THE CHAPTER & COMMENCING THE CASE

  • 8.1 In general
  • 8.2 Time between bankruptcies extended
  • 8.3 Mandatory chapter 13
  • 8.4 Optional chapter 13
  • 8.5 Treatment of claims in chapter 13
  • 8.6 Calculating the chapter 13 plan payment
  • 8.7 Post-petition filing requirements for chapter 13
  • 8.8 Attorneys' fees in chapter 13
  • 8.9 The confirmation hearing
  • 8.10 Additional hearing required for chapter 13 discharge
  • 8.11 Preparation of documents to file
  • 8.12 Chapter 7
  • 8.13 Counseling the client
  • 8.14 Filing the case
  • 8.15 New notice requirements
  • 8.16 Effect of the automatic stay
  • 8.17 Calendar critical deadlines
  • 8.18  The meeting of creditors

STEP 9

THE MEETING OF CREDITORS

  • 9.1 In general
  • 9.2 Hearing on confirmation of chapter 13 plan
  • 9.3 Notice of meeting of creditors
  • 9.4 Creditor representation at meeting
  • 9.5 Tax returns required in chapter 13
  • 9.6 Return or transcript provided to trustee
  • 9.7 Perform intentions
  • 9.8 Perform intentions
  • 9.9 U.S. Trustee post-moc review
  • 9.10 Advise the debtor

STEP 10

POSTPETITION ISSUES & TASKS

  • 10.1 In general
  • 10.2 Postpetition deadline checklist
  • 10.3 Motion to prevent termination of stay
  • 10.4 Perform intentions - reaffirm or redeem
  • 10.5 Motion to dismiss or convert under ¬ß 707(b)
  • 10.6 Provide copy of most recent federal tax return
  • 10.7 File 4 years of prepetition returns in chapter 13
  • 10.8 File all postpetition tax returns
  • 10.9 Different definitions of tax returns
  • 10.10 Motion to extend time
  • 10.11 Assume or reject lease or executory contract
  • 10.12 Cure of lease default
  • 10.13 Proof of adequate protection
  • 10.14 Annual income & expense statement
  • 10.15 The postpetition credit briefing
  • 10.16 The pre-discharge hearing in chapter 13
  • 10.17 Notice of insurance coverage to secured creditors
  • 10.18 The financial management course
  • 10.19 Notice of amended schedules
  • 10.20 File proof of claim for taxes
  • 10.21 Hearing on plan confirmation
  • 10.22 Notice of meeting of creditors
  • 10.23 Lookback period for fraudulent transfers extended
  • 10.24 Avoiding transfers to trusts
  • 10.25 Certain payments not avoidable as preferences
  • 10.26 Conversion of chapter 13 to chapter 7
  • 10.27 Certain documents filed not later than 45 days after case filed
  • 10.28 Dismissal of chapter 7 where debtor convicted of certain crimes
  • 10.29 Purchase-money lien avoidance

APPENDIX

FLOW CHARTS

  • Flow-chart #1 - Handling a case
  • Flow-chart #2 - Handling a case cont'd
  • Flow-chart #3 - Figuring disposable income
  • Flow-chart #4 - The means test
  • Flow-chart #5 - Another means test chart
  • Flow-chart #6 - The credit briefing
  • Flow-chart #7 - The state exemptions
  • Flow-chart #8 - Calculating the Chapter 13 plan payment
  • Flow-chart #9 - When are Disclosures Required?

CHECKLISTS

  • Checklist # 1 - Preparation for practice under the Act
  • Checklist # 2 - Client interview checklist
  • Checklist # 3 - Documents to request from client
  • Checklist # 4 - Documents to file
  • Checklist # 5 - Deadline checklist - 22 items
  • Checklist # 6 - Debtor's post-petition duties
  • Checklist # 7 - Duties of a debt relief agency
  • Checklist # 8 - Look-back time periods
  • Checklist # 9 - Debtor's motions
  • Chgecklist # 10 - New grounds for dismissal
  • Checklist # 11 - Bodow's Chapter 7 Interview Checklist
  • Checklist # 12 - Bodow's Chapter 13 Interview Checklist
  • Checklist # 13 - Additional Time Increments
  • Checklist # 14 - Certifications to file
  • Checklist # 15 - Traps For The Unwary

DISCLOSURE STATEMENTS

  • Disclosure  # 1 Per § 527(b)
  • Disclosure  # 2 Per §527(a)(1) & 342(a)(2)
  • Disclosure  # 3 Per §527(a)(2)
  • Disclosure # 4 Per §527(c)
  • Disclosure # 5 Per §342(b)(2)(A) & (B)
  • Disclosure # 6 Per § 524(k)

PLUS

  • Yerbich Synopsis of Key Changes in The Code
  • O. Max Gardner's Chapter 7 Fee Agreement
  • O. Max Gardner's Chapter 13 Fee Agreement
  • Certification of Request For Waiver of Pre-Petition Credit Counseling
  • Certification of completion of Financial Management Course
  • Motion To Continue Automatic Stay

THE CD

  • Official Rules
  • Official Forms
  • Calculators
  • IRS standards and other information
  • Checklists
  • Flow-charts
  • Texts of Guide, The Reform Act, and other material
  • Other forms
  • Miscellaneous

 

WHAT THEY'RE SAYING ABOUT THIS BOOK

"I am very much looking forward to receiving what has been termed "The Holy Grail" of bankruptcy information! Everyone I have spoken with has recommended that I purchase your materials as they are the most thorough and up-to-date, and I hope to attend one of your bankruptcy classes in the very near future. " - Jill McDonald, So. Pasadena, FL Sept. 2008.

"I've utilized several different bankruptcy texts, treatises, etc., and none compare to yours, at least to satisfy my own comfort level.  Thanks for putting such a quality product on the market." - Steven R. Zweigart, Flemingsburg, Kentucky  July 7 2008

 "I just submitted an online order.  Anything you can do to get it to me as soon as possible would be greatly appreciated. I do not feel comfortable starting to practice under the new law w/out reading your Guide, et al first. Thanks for all you're doing for bk practitioners" - Mark F. Viencek, Rochester, NY

"Your Guide has been referred to as "My Bible" many times.   The first guide went everywhere with me for almost a year -- except home to my parents for Christmas. " - Barbara Janzen, Leawood, KS

"Your books have been a godsend." - Jordan Rappaport, Boca Tatan, FL.

"I don't want to fall behind in the new world of BAPCPA and, accordingly, go to the "master" to get my information which is always concise and well written. I, and many other practitioners, sincerely appreciate your publications and efforts." - Gerald H. Davis, Bankruptcy Trustee, Palm Springs, CA

"I really appreciate the great information you provide for us bankruptcy attorneys. As a solo, I don't think I would make it without your resources. Thank you!" - Alexis Crow, Charlottesville, VA

"I will forward you the email that was circulated on our listserve that said we were committing malpractice if we were filing bankruptcies without your guides!" - Teresa Kidd, Shawnee, KS

"I can say that I have seen no other text on the new bankruptcy law that remotely comes close to yours in usability for bankruptcy practitioners." - Gary R. Fraley, Sacramento, CA

"Kings Guide to BAPCPA has proven itself to be the most valuable resource in the office. Although I have taken 4 CLE courses to prep. for 10/17/05 and its aftermath,the book anticipated many of the rulings now coming down." - William Wolfson, Flemington, NJ

"Your materials are essential to the practice of bankruptcy law under BAPCPA." - Robert W. Raley, Bossier City, LA

"I recommend your book to everyone. It is amazing what you have put in it!" - John Bates, New Philadelphia, OH

"The Guide is remarkably well done and comprehensive.". - George Arnold, Evanston, WY

"I received it today and began reading immediately. It is a wonderful manual and wish I had the foresight to have ordered it earlier." David Zaffina, Hazel Park, MI

"The King expertise has saved many a bankruptcy attorney from going nuts. I handle only small business and tax cases have 25 plus years experience and the King guide is something I could not do without. I would endorse Morgan's books anytime. Thank you for all the hard work in giving us something practical and well researched. When the law changed and you came out with the Reform Guide, I knew I had to have it. It helped me feel competent getting back to work" - Marguerite Kirk Fort Worth,TX Board Certified Business Bankruptcy American Board Bankruptcy Certification, Board Certified consumer Bankruptcy Texas since 1987.

"I have been a practicing consumer bankruptcy lawyer for almost 20 years.  When the 2005 BAPCPA law was enacted, I had almost come to the conclusion that my bankruptcy practice was over - the text of the new law is confusing, contradictory and often internally inconsistent.  Morgan King's Guide to the 2005 BAPCPA is the main reason I am still in practice. Mr. King's Guide offers a step by step, practical roadmap for practice under the new laws.  I refer to it constantly.  I cannot see how any consumer bankruptcy law practitioner could possibly navigate the minefield of post-BAPCPA practice without this Guide.  It contains checklists, spreadsheets, client handouts and substantive comment.  I frequently teach continuing education seminars about bankruptcy to other lawyers and my first recommendation is to purchase Mr. King's Guide." - Jonathan Ginsberg, Atlanta, GA."

"King's Manual is a must. I read it cover to cover and should probably do it again." - David Shaev, N.Y., N.Y.

"Get Morgan's book on BARF. I wouldn't practice without it." - Milton D. Jones, Morrow, GA.

"The book really has saved me." - Ron Satija, Austin, TX

"If you could, please overnight them!  I have heard rave reviews from the folks on the NACBA list and I really could use all the help I can get with this new freaking law.. I have a few post-BARF cases I am starting to work on and I would 'prefer' not to screw up on my first filings." - Shannon Foster, West Chester, PA

"I have yet to see anyone but you offer a good guide on how to gear up for the new law. I bought yours and thought it was very good, and have probably sold at least 5-10 via my endorsements and recommendations." - James Cossitt, Kalispell, MT

"I was euphoric on how well the material is presented." - Wayne Bodow, Syracuse, N.Y.

"You're getting unanimously wonderful feedback on your book!" - Jed Berliner, Springfield, MA

"The book removes the fear . . . you've truly written a map. There's little left to chance. With the checklists and outlines, it's pretty difficult to miss something important and that provides a needed level of comfort." - Adam Schachter, Houston, TX

"Morgan King (not-related and I don't get a commission) has put together an extremely useful guide to practice under the new law. It includes all kinds of wonderful checklists, sample agreements for services, sample handouts and other materials. And pretty much walks you through everything you need to do to be ready to practice under the new law.  It costs a little less than $200 I think and is worth every penny of it. I commend it to your attention." - Jerry Harper, Topeka, KS

"The "Guide to Practice" under BARF is a terrific book, very helpful, lots of checklists and suggestions, flow charts, etc." - D. Jacobs, Chico Ca.

"Many thanks. Excellent book. Much more useful than any of the other BAPCPA manuals." - George C. Heck, Old Lyme, CT

"The binder has been extremely informative in describing the drastic changes that will soon occur. I am glad that we purchased this binder." - N. Siegel, Santa Ana, CA

"This book is an essential tool for all consumer bankruptcy lawyers." - O. Max Gardner, Shelby, NC

"The new laws seemed intimidating before. After reading your guide, I am not too troubled by them." - S. Lanin, NY NY

"... text seems very comprehensive and helpful." M. Gunnar, Hilliard, OH

"I've found your guide very informative, and only apologize for not letting you know sooner. The guide will be instrumental in helping me prepare for the changes coming." - S. Flood, Muskogee, OK

"I definitely like the stepwise approach to the manual. It makes for a nice progression and it is easy to stay oriented to the material and makes it easy to understand how and where existing practice will change." G. Heck, New London, Connecticut

"Excellent." H. Goldstein, Sarasota, FL

"... very easy to read and follow." D. Patrick, Lynnwood, WA

"I received Morgan's book this afternoon in a reasonable time after ordering. The flow charts, checklists, and disclosure statements alone will save my small office a lot of (nonbillable) time as we finalize preparations to deal with the new law. I strongly recommend it to you for your consideration. I have no financial interest in the book." Roger Cotner, Grand Haven, MI

"I will definitely buy your books as soon as they are available. I have bought some of your books before and I love them!" - Modesto Lopez, Orlando, Florida

"Excellent job!" - Mark Westbrooks, Phoenix, AZ

"I recently attended a panel put on by the chapter 7 trustees. Your presentation of the median income and means tests were much better than what was given to the Trustees." - Anon. (for obvious reasons)

"The Guide to Practice Under the Bankruptcy Reform Act of 2005 has been a tremendous resource.  I am a new attorney who has been doing a self-tutorial on how to practice law in the bankruptcy field.  Your guide has helped me a great deal." - James Kennedy, Laconia, NH.

 


The book comes bundled with the CD library -

CONTENTS OF CD LIBRARY THAT COMES
WITH THE GUIDE
 

Folder 1: Interim Official Rules

Folder 2: New Official Forms

  • Form 22A
  • Form 22B
  • Form 22C
  • Form 23
  • Form 24
  • Form 19B
  • Form 3B

Folder 3: Calculators

  • 6-month gross income spreadsheet
  • 6-mont gross income calculator
  • Current monthly income (CMI) calculator
  • Means test calculator by EZ-Filing
  • Means test calculator by EZ-Filing ver. 2
  • Means test calculator
  • Means test calculator
  • Calendar date calculator
  • BAPCPA Date Calculator
  • Simple homestead exemption calculator
  • Current Monthly Income calculator
  • Simple homestead exemption calculator

Folder 4: Checklists

  • Checklist # 1 - Preparation for practice
  • Checklist # 2 - Client interview checklist
  • Checklist # 3 - Documents to request
  • Checklist # 4 - Documents to file
  • Checklist # 5 - Deadline checklist - 22 items
  • Checklist # 6 - Debtor's post-petition duties
  • Checklist # 7 - Duties of a debt relief agency
  • Checklist # 8 - Look-back time periods
  • Checklist # 9 - Debtor's motions
  • Chgecklist # 10 - New grounds for dismissal
  • Checklist # 11 - Bodow's Chapter 7 Interview
  • Checklist # 12 - Bodow's Chapter 13 Interview
  • Checklist # 13 - Additional Time Increments
  • Checklist # 14 - Certifications for filing
  • Checklist # 15 - Traps For The Unwary
  • Paul Snyder's Document Request Checklist

Folder 5: Flow-charts

  • Chart #1 - Handling a case
  • Chart #2 - Handling a case cont'F
  • Chart #3 - Figuring disposable income
  • Chart #4 - Means test
  • Chart #5 - Means test, alternate chart
  • Chart #6 - The credit briefing
  • Chart #7 - Figuring the homestead exemption
  • Chart #8 - Calculating the chapter 13 plan payment
  • Chart #9 - When Must Disclosures Be Given?

Folder 6: Texts on pdf

  • Full text Guide To Practice Under The Bankruptcy Reform Act
  • Full text of BAPCPA
  • Full text House Judiciary Committee Report S256 H.R. 109-31
  • Full text House Judiciary Democrats' Dissent
  • Thomas Yerbich Section-by-Section Synopsis of the Act
  • Full text The NACBA analysis of the Reform Act
  • Full text CRS Report For Congress Feb. 3 2005

Folder 7: IRS Resources

  • Text of the IRS Manual chapter on Financial Collection Standards
  • IRS Form 4506 Request For Information
  • IRS Form 4506-T Request For Transcript of Return
  • IRS Form 2848 Power of Attorney
  • IRS Form 8821 ‚ Tax Information Authorization

Folder 8: Other forms

  • Credit Counseling Waiver Certification
  • Consent to Release Credit Report
  • Credit Counseling Certification
  • Order re: Request For Continuation of Automatic Stay
  • Certification of Filing

Folder 9 - Fee agreements

  • Initial Consultation fee agreement
  • Chapter 7 fee agreement
  • Chapter 13 fee agreement

Folder 10 - Miscellaneous

  • Judge Davis' Order
  • O. Max Gardner CMI Statement
  • O. Max Gardner's Vehicle Information Form

 


© King Bankruptcy Media 2005