Creditor claimed the debt owed it by chapter 7 debtor was non-dischargeable under 11 U.S.C. § 523(a)(2), but the bankruptcy court held that creditor's forbearance from calling his demand note did not constitute an extension, renewal, or refinance of credit within the meaning of § 523(a)(2). Creditor appealed, and the district court held that, if proven, a creditor's forbearance from demanding payment of a demand note, resulting from creditor's reliance on debtor's false statements, would constitute an extension of credit subject to § 523(a)(2). Since creditor had claimed that he did not demand payment because debtor provided him with false financial statements, his claim was that those statements allowed debtor to continue the parties' debtor-creditor relationship, which was an extension of credit subject to § 523(a)(2). The case was remanded to the bankruptcy court for determinations of fact with respect to whether debtor's statements were false and intended to deceive creditor and, if so, whether creditor's reliance on them was reasonable.