Eighth Circuit Says Paying Unsecured Non-Dischargeable Tax Debt In Full While Paying 0% to Other Creditors Is Unfair Discrimination

“Attending the NACTT Annual Seminar provided the opportunity to catch up with Chapter 13 colleagues from around the country who are quickly becoming good friends; and to build relationships with colleagues who have recently joined our niche’ of the bankruptcy field.”

On April 8, 2026, the Chief Justice sent an Order to Congress, notifying that the Supreme Court had approved amendments of several Federal Rules of Bankruptcy Procedure that would be effective December 1, 2026, unless Congress acted otherwise. It is not expected that Congress would take action to prevent the amended Rules taking effect.

Chapter 13 debtor may modify confirmed plan, both to reduce payments and shorten length of plan even though the debtor had above-median income at the time of confirmation but below median income, at the time of modification.

Attorney Hayes is back again this week to discuss when a chapter 7 debtor can strip down or strip off a consensual lien?

Consumer bankruptcy lawyers are seeing clients with solar panel debt. In Part 1 of his article, Mark Leffler provides a background for multi-district class action litigation in Minnesota and other enforcement actions by Attorneys General in Minnesota and Virginia concerning the financing of rooftop solar panels. Part 2 of his article will appear next week, and in that Part the author examines legal issues underlying the fraud claims in the litigation.

This is a potential BIGGIE . . . Where a Chapter 13 debtor incurs one relatively small expense covered by the IRS Local Standards, the debtor is entitled to deduct from CMI the entire allowance to calculate Projected Disposable Income.

“ . . . practice and procedure accomplishing the lien strip have been slow to evolve since 2017. . . . in the jurisdictions that opted out of usage of the Form 113 Plan, multiple iterations for lien stripping and release are found.”