In re Henderson, 472 B.R. 579 (Bankr. D. Colo. 2012) (Brown)

Chapter 7 discharge within four years rendered debtors ineligible for Chapter 13 discharge—notwithstanding post-discharge conversion of prior Chapter 7 case to Chapter 13 and subsequent dismissal. Section 349 says that dismissal does not bar discharge in later case unless court ordered otherwise, but legislative history indicates that statement refers only to predischarge dismissals. Debts discharged in prior Chapter 7 case remained discharged, but debts incurred after filing of prior case would not be dischargeable on plan completion, unless paid in full.

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