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Asset Exempt in Chapter 13 Retains the Exemption After Conversion, First Circuit Says

Circuit split is eroding on the loss of a homestead exemption for failing to reinvest proceeds from a sale after filing.
Court: 

Ninth Circuit Creates a Legal Fiction to Uphold Recovery of an Unauthorized Transfer

Ninth Circuit assumed that transferred property must remain property of the estate after conversion from ‘13’ to ‘7’ before the chapter 7 trustee can avoid an unauthorized transfer under Section 549.
Court: 

Courts Reject BAP Opinion on Estate Property When Individuals Convert from 11 to 7

Individuals in chapter 11 who convert to chapter 7 come out worse that those who convert from chapter 13.
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