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197 (x) the court approves a written waiver of discharge executed by the debtor after the order for relief under Chapter 7; (xi) after filing the Chapter 7 case, an individual debtor fails to complete an instructional course in personal financial management; or (xii) the court finds that there is reasonable cause to believe that (a) Section 522(q)(1) of the Bankruptcy Code (which prevents individuals who have engaged in criminal conduct from shielding their homestead assets from those whom they have defrauded or injured) may apply to the debtor and (b) there is pending any proceeding in which the debtor may be found guilty of a felony or liable for a debt of the kinds described in Section 522(q)(1). 11 U.S.C. § 727(a)–(b). Of particular note, although individuals who are liquidating under Chapter 7 can receive a discharge (provided that no other ground for denial of a discharge is applicable to them), corporations and other entities who are liquidating under Chapter 7 cannot. Parties in interest, including creditors, the trustee and the U.S. Trustee, may object to the granting of a discharge and can also request revocation of a discharge. 11 U.S.C. § 726(c)–(d). As a general matter, if granted, the discharge both eliminates the debtor's personal liability for all non-exempt debts and enjoins creditors from attempting to collect such debts. Many courts have construed the discharge provisions favorably to debtors. See Republic Credit Corp. I v. Boyer (In re Boyer), 328 F. App'x 711, 714 (2d Cir. 2009) (noting that the objecting creditor bears the burden to prove that the debtor violated section 727). The procedures governing matters related to discharge, including the grant or denial of discharge, objections to discharge and the burden of proof related thereto, are set forth in Bankruptcy Rules 4004 through 4007.

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