In re Van Winkle, No. 11-13861-j13, 2012 WL 404956 (Bankr. D.N.M. Feb. 8, 2012) (Jacobvitz)

Although some courts have held that debtor may not fund plan solely from sale of property, Code does not explicitly prohibit funding through asset liquidation, and § 1322(b)(8) provides that plan may provide for payment of all or part of claim from property of estate or of debtor. Debtor agreed to pay 100%, plus 3% interest on unsecured claims, waiving homestead exemption and selling assets, as necessary.

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