Critical Case Comment

By Henry E. Hildebrand, III, Chapter 13 Trustee for the Middle District of Tennessee

In re Stewart, No. 13-33037 HCD (Bankr. N.D. Ind. Filed August 26, 2014) (Dees). When a below-median income debtor establishes good cause permitting the extension of a Chapter 13 plan beyond 36 months, the debtor must commit all projected disposable income to the plan for the entire term of the plan.

Case Summary

Ms. Stewart filed a Chapter 13 plan as a below-median income debtor and proposed to make no distribution to unsecured creditors, pay priority claims in . . .

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