From the Editor’s Desk – Conversion and Dismissal • NACTT Academy

From the Editor’s Desk – Conversion and Dismissal

By The Honorable William Houston Brown (Retired)

Failure to timely commence plan payments was cause for dismissal. Pro se debtor’s failure to commence plan payments within 30 days from the order for relief, as required by § 1326(a)(1), was itself cause for dismissal under § 1307(c)(4). The debtor had been given an opportunity at a hearing to provide an excuse, but none was given. The debtor also failed to attend the § 341 meeting of creditors. Witkowski v. Boyajian (In re Witkowski), ___ B.R. ___, 2014 WL 5933979 (BAP 1st Cir . . .

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