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ABI Journal

1327

Another Court Lets the Debtor Keep Appreciation in a Home on Conversion from 13 to 7

Where the courts are split, Idaho judge sides with the Tenth Circuit BAP and allows a chapter 13 debtor to retain post-petition appreciation in the value of a homestead following conversion to chapter 7.

Fourth Circuit Stands Alone in Limiting Chapter 13 Plan Modifications

Eleventh Circuit joins the majority of circuits by holding that unforeseen, changed circumstances are not required to modify a chapter 13 plan.