From the Editor – An Assortment

By The Honorable William Houston Brown (Retired)

Postpetition Property of Estate - Inheritance received more than 180 days postpetition included in property of estate. Section 1306(a)(1) broadens § 541(a)’s definition of property of the estate, to include all property acquired after commencement of the case, not limited by § 541(a)(5)’s 180-day postpetition limit, agreeing with Carroll v. Logan, 735 F.3d 147 (4th Cir. 2013). The inheritance must be turned over, unless the debtors modified their plan to increase distribution to unsecured creditors. Dale v. Maney (In re . . .

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