By Academy Staff Phil was a quiet, humble man. He loved his family, loved the law, and loved to serve others. Philip D. Lamos, age 53 of Painesville Township, passed away suddenly on June 11, 2021. He was a hometown boy who loved his family, especially his son Matthew and daughter Emily. Phil was a graduate of John Carroll University...
From the Editor – Modification
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By The Honorable William Houston Brown (Retired)
Postconfirmation modified plan not required to comply with projected disposable income test. After confirmation of above-median debtor’s plan, debtor’s income decreased and he moved to modify to reduce term of plan and distribution to unsecured creditors. The court concluded that § 1329(a)(2) permits shortening of plan term and that § 1325(b)’s projected disposable income is not enumerated in § 1329(b)(1)’s modification requirements. The split of authority on the issue was discussed, concluding that “the inclusion of section 1325(b) in the requirements . . .
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