By Lawrence R. Ahern III, Brown & Ahern (Nashville, TN) Introduction This year's changes in the Rules of Bankruptcy Procedure are summarized below. They will be followed, in Part 2, by a digest of selected judicial decisions in the past year of interest for their procedural implications. December 1, 2021, Amendments to Bankruptcy Rules 2005, 3007, 7007.1 and 9036 On...
From the Editor’s Desk – Plan Modification
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By The Honorable William Houston Brown (Retired)
Motion to modify too late. In a case in which plan payments had been completed the trustee’s motion to modify, in order to capture a postpetition inheritance, was too late, with modification denied. The court held that § 1329(a) must be construed to refer to when actual plan payments were completed, rather than to when the trustee submitted a notice of completed plan payments. In re Zisumbo, 519 B.R. 851 (Bankr. D. Utah 2014).
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The Honorable William Houston Brown retired in 2006 as a . . .
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