Did Congress Mean What It Said in Section 1328(i)?

By Pardis Akhavan, Resnik Hayes Moradi LLP (Encino, CA)

The bankruptcy court in In re Ritter, 2021 WL 864092 (Bkrtcy C.D. Cal, 2021)(J. Tighe),denied debtors’ motion for an immediate discharge under Section 1328(i) ruling that Congress apparently did not intend that a chapter 13 debtor who obtains a loan modification should also receive a discharge, on that basis alone at least.

Allen and Debra Ritter filed their Chapter 13 petition on July 21, 2019. Their Chapter 13 plan was confirmed about . . .

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