Beth E. Hanan | ABI

Plans Longer than 5 Years Can’t Be Amended Now Because Section 1329(d) Has Expired

A plan longer than five years must revert to a five-year plan now that Congress has allowed Section 1329(d) to expire, Judge Hanan says.

Court :

Wisconsin Eastern District

Discharge Cuts Off Future Liability on a Guaranty, Some Courts Hold on a Split

The ‘conduct’ test in the Seventh Circuit, not the ‘accrual test,’ determines when a claim arose and whether it was discharged.

Court :

Wisconsin Eastern District

Reimbursed Expenses Included in Calculating Median Income for Plan Duration

Debtor kicked into longer plan as a consequence of employer’s expense reimbursements.

Court :

Wisconsin Eastern District

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