Law360, New York (July 01, 2013, 5:52 PM ET) -- One of the primary purposes of bankruptcy is to provide for the discharge of certain debts in order to enable a debtor to obtain a “fresh start” post-bankruptcy. Notwithstanding this specific purpose, section 523 of Title 11 of the United States Code, 11 U.S.C. § 101 et seq. (the Bankruptcy Code), provides that certain debts may not be discharged, including debts incurred by “fraud or defalcation while acting in a fiduciary capacity, embezzlement or larceny.” 11 U.S.C. § 523(a)(4).