Critical Case Comment

By Henry E. Hildebrand, III, Chapter 13 Standing Trustee for the Middle District of Tennessee (Nashville)

Chapter 13 debtor may include a provision in the Chapter 13 plan that only estimates the duration of the plan and, absent an objection, such provision would cause the debtor’s plan to terminate and the debtor receive a discharge when the claims have been otherwise satisfied. In re Sisk, 962 F.3d 1133 (9th Cir. June 22, 2020) (Bumatay)

Case Summary

In a number of cases, debtors proposed plans which took advantage of the debtors’ ability to modify the . . .

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