From the Editor’s Desk – Plan Modification

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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