Undue hardship is defined by whatever the courts in your jurisdiction define it as.
In most courts, the "Brunner" test is used which requires you to prove the following:
1. that you cannot maintain, based on current income and expenses, a 'minimal' standard of living for yourself and your dependents if forced to repay the loans;
2. that additional circumstances exist indicating that this state of financial affairs is likely to persist for a significant portion of the repayment period of the student loans; and,3. that you made good faith effort to repay the loans.
This does not just include making payments on the loans. It requires doing things over time such as making efforts to increase your income (which includes going back to school to get additional degrees or experience), consolidating loans with the Direct Loan Servicing Center, and other similar efforts.
I don't know what the courts in Georgia use as their criteria, but there is an easy way to find out: Have a consultation with a bankruptcy attorney in your area!
Mark Markus has been practicing exclusively bankruptcy law in California since 1991. He is a Certified Specialist in Bankruptcy Law by the State Bar of California Board of Legal Specialization, AV-Rated by martindale.com, and A+ rated by the Better Business Bureau.
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