From the Editor’s Desk – Conversion and Dismissal

By The Honorable William Houston Brown (Retired)

Dismissal did not deprive court of sanction authority. The Chapter 13 case was dismissed after the debtor’s testimony that he had not received regular monthly financial assistance from his partner, as had been stated in the schedules, and a creditor subsequently filed a motion for sanctions against the debtor and debtor’s attorney. The court held that the case dismissal did not deprive the court of authority to consider an award of sanctions. The debtor was never eligible for Chapter 13 relief, since he lacked regular income, and . . .

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