By Dynele Schinker-Kuharich, Chapter 13 Standing Trustee (Canton, OH) I vividly remember getting the call that I was to be appointed as a Standing Chapter 13 Trustee (effective October 1, 2018). I was so honored, and humbled, and excited. At the time I was a panel Chapter 7 Trustee, but my heart had always been in Chapter 13. As corny...
From the Editor – Dismissal
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By The Honorable William Houston Brown (Retired)
Undistributed funds returned to debtor upon dismissal. Under § 1327(b)’s vesting requirement, unless a confirmed plan provides otherwise, any undistributed funds held by the trustee at dismissal of the case must be returned to the debtor. Although not necessary to rely on § 347(b)(3), the conclusion on effect of vesting at confirmation was consistent with that section and case law interpreting it. In re Hernandez, _________B.R._________, 2020 WL 773475 (Bankr. D. Conn. Jan. 17, 2020). See also In re Evans, _________B.R._________, 2020 WL . . .
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