Section 548(a)(2)(A) of the federal Bankruptcy Code, added by the Religious Liberty and Charitable Donation Protection Act of 1998, protects charitable contributions up to 15% of the debtor’s gross annual income and prevents creditors from recovering the donations to pay the debtor’s bills. But a Bankruptcy Appellate Panel in the 10th Circuit has been called upon to interpret what the section means. Does it mean that donations are protected up to the aggregate of 15% of income but not beyond, or does it mean that gifts of more than 15% are not protected at all? Rejecting a decision by a bankruptcy court in Louisiana that held a single contribution of more than 15% of annual income was...