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.
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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.
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