In re Airhart, 473 B.R. 178, 185 (Bankr. S.D. Tex. 2012) (Bohm)

After BAPCPA, valuation of collateral begins anew at conversion to Chapter 7 for purposes of redemption. Creditor made tactical error by relying solely on N.A.D.A. value, without considering adjustments based on mileage and condition. Chapter 7 debtor succeeded at redeeming vehicle for significantly less than secured claim balance. “If Right Choice had simply done more than robotically rely upon the N.A.D.A. Appraisal Guide, it might have improved its chances of convincing this Court that the redemption value is higher . . . . Or, if Right Choice had simply inspected the Tundra, it might have concluded that it should attempt to negotiate a settlement with the Debtor and reach an agreement on a redemption value higher than [amount fixed by court].”

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