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)
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 . . .
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