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From the Editor – Chapter 13 Issues
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By The Honorable William Houston Brown (Retired)
Effect of Confirmation: Disputed claim “provided for” by plan. The debtor and creditor had been involved in litigation for years, and the plan specifically stated that no payment of the disputed claim would be made, but that if the creditor prevailed in obtaining judgment and then filed a proof of claim, the plan would be amended to reflect the status. The nonbankruptcy litigation continued, and the plan was never amended, nor was a final amended proof of claim filed. The plan was completed, with no payment to this disputed . . .
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