The NACTT Academy offers a comprehensive community for bankruptcy professionals seeking to advance their education in consumer bankruptcy.
ConsiderChapter13.org offers a forum to advance continuing education of consumer bankruptcy via access to insightful articles, informative webinars, and the latest industry news. Join now to benefit from expert resources and stay informed.
These informative sessions are led by industry experts and cover a range of consumer bankruptcy topics.
Written by industry experts, these articles provide in-depth analysis and practical guidance on consumer bankruptcy topics.
The Academy is the go-to source for the latest news and analysis in the Chapter 13 bankruptcy industry.
Critical Case Comment – Pre-Confirmation Payments
Print This Article
Link to Post:
Even though the Model Plan in the district provides that the applicable commitment period starts from confirmation, the debtor may not apply pre-confirmation payments toward payments made during the applicable commitment period but must apply those payments in addition to the applicable commitment period payments. (Applebaum) In re Batoha, 2022 WL 1310943 (Bankr. E.D. Mich. May 2, 2022)
Case Summary
Brett Batoha filed Chapter 13in November of 2021. He filed a plan and commenced making payments pending confirmation.
In the Eastern District of Michigan, the adopted Model Plan provides . . .
It looks like you are not signed in or registered! This content is only available to members.
Or Sign In Below:
Henry E. Hildebrand, III
Chapter 13 Standing Trustee for the Middle District of Tennessee (Nashville)
Henry E. Hildebrand, III has served as Standing Trustee for Chapter 13 matters in the Middle District of Tennessee since 1982 and as Standing Chapter 12 Trustee for that district since 1986. He also is of counsel to the Nashville law firm of Belcher Sykes Harrington, PLLC. Mr. Hildebrand graduated from Vanderbilt University and received his J.D. from the National Law Center of George Washington University. He is a fellow of the American College of Bankruptcy and the Nashville Bar Foundation. He is Board Certified in consumer bankruptcy law by the American Board of Certification and serves on its faculty committee. He is Chairman of the Legislative and Legal Affairs Committee for the National Association of Chapter 13 Trustees (NACTT). He is on the Board of Directors for the NACTT Academy for Consumer Bankruptcy Education, Inc. and is an adjunct faculty member for the Nashville School of Law and St. Johns University School of Law. In addition, he served as a commissioner to the American Bankruptcy Institute’s Commission on Consumer Bankruptcy.
Related Articles
These Summer Activities Can Affect Next Year’s Tax Returns
Judge Carol A. Doyle: Pre-Retirement Interview
Consumer Foreclosure Procedures
Critical Case Comment – Service Counts
Sub V Update
What Defines a Petition Preparer
ABI Commission on Consumer Bankruptcy – Student Loans – Suggested Statutory Changes
From the Editor
Critical Case Comment
Use All Channels to Educate Bankruptcy Debtors