Can a Debtor Cram Down a Plan Under the Indubitable Equivalent Standard Where the Plan Modifies the Terms of the Creditor’s Loan? Highly Unlikely
This specific question was faced by the United States Bankruptcy Court for the District of Arizona in the case of In re Saguaro Ranch Development Corp., 2011 WL 2182416 (Bankr. D. Ariz. June 1, 2011). In Saguaro, the Debtor owned a large real estate