By Academy Staff Jan P. Johnson served as a Chapter Standing 13 Trustee for the Eastern District of California, Sacramento Division, from 1998 to September 30, 2019. Prior to this appointment, he served as Chapter 13 Standing Trustee for the District of Puerto Rico from 1989 where he was responsible for over 25,000 cases. He was also appointed as Standing...
Under 1329 the ‘Disposable Income Test’ Applies In A Post-Confirmation Plan Modification – Doesn’t It?
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By Joseph A. Bledsoe, III, Chapter 13 Standing Trustee for the Eastern District of North Carolina
Recently, I had a spirited conversation with a reputable debtors’ attorney regarding the application of 11 U.S.C. § 1325(b) to a post-confirmation plan modification under 11 U.S.C. § 1329. Now, I know this topic is old news for most of you, and that courts have been considering this issue since before I got my law license, but please stay with me.
I received a proposed modification and emailed the debtors’ attorney to request some supporting documentation – namely, an . . .
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