The following excerpt is from In re Kabel, 184 BR 422 (Bankr. W.D. N.Y. 1992):
5 Prior to the case of Grogan v. Garner 498 U.S. 279, 111 S.Ct. 654, 112 L.Ed.2d 755 (1991), the burden of proof in 523(a)(2) cases was "clear and convincing evidence" in some jurisdictions. That case sets ordinary "preponderance" as the pertinent standard.
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