The following excerpt is from In re Kritt, 190 BR 382 (B.A.P. 9th Cir. 1995):
Combs, 101 B.R. at 616. See also Brody v. Brody (In re Brody), 3 F.3d 35, 38-39 (2d Cir.1993) ("The parol evidence rule does not apply in cases such as the instant one, and factual inquiry under section 523(a)(5) is not limited to the four corners of a separation agreement or divorce decree.").
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