What is the current state of the law in relation to the interpretation of Section 727 of the Bankruptcy Code?

In re Devers, 759 F.2d 751, 754-55 (9th Cir. 1985). "In keeping with the 'fresh start' purposes behind the Bankruptcy Code, courts should construe 727 liberally in favor of debtors and strictly against parties objecting to discharge." In re Bernard, 96 F.3d 1279,1281 (9th Cir. 1996) (citing In re Devers, 759 F.2d at 754). And "[t]he burden of proof in an adversary proceeding objecting to discharge under 727 is preponderance of evidence." In re Searles, 317 B.R. 368, 376 (B.A.P. 9th Cir. 2004) (citing Grogan v. Garner, 498 U.S. 279, 289 (1991)).