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Fifth Circuit Adopts Flexible Timing for Section 1111(b) Cramdown Valuation

Fifth Circuit refuses to adopt chapter 13 valuation timing to chapter 11 cramdowns.
Court: 

Chapter 13 Strip-Off Ok Even if Lienholder Does Not File a Claim, Fourth Circuit Holds

A contrary result would have obviated the judicially recognized right to strip off underwater subordinate liens in chapter 13.
Court: 

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