In re Craver, No. 11-62129, 2012 WL 290366 (Bankr. N.D. Ohio Jan. 31, 2012) (Kendig)

For hypothetical Chapter 7 liquidation, used vehicle was valued at wholesale—what Chapter 7 trustee would likely obtain if vehicle were auctioned. Associates Commercial Corp. v. Rash, 520 U.S. 953, 117 S. Ct. 1879, 138 L. Ed. 2d 148 (June 16, 1997), adopted replacement value for cramdown but did not require particular benchmark for other purposes. Liquidation recovery was adjusted for exemptions in property and 10% cost of sale and administrative cost in hypothetical Chapter 7.

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