By The Honorable William Houston Brown (Retired)
Section 506(d) applies in Chapter 13. Agreeing with In re Woolsey, 696 F.3d 1266 (10th Cir. 2012), the Seventh Circuit held that § 506(d) applies in Chapter 13, and Dewsnup v. Timm, 502 U.S. 410 (1992), did not distinguish between Chapter 7 and 13 cases, preventing the debtor from using § 506(d) as a means to void a partially secured IRS tax lien. The court noted that Chapter 13 provides alternative means of avoiding liens. Ryan v. United States (In re Ryan), ____ F.3d ____, 2013 WL . . .
It looks like you are not signed in or registered! This content is only available to members.
Or Sign In Below: