Where a debtor fails to disclose to the Court or the trustee a forbearance on his mortgage that he was to pay directly, the Court would grant the trustee’s motion to modify to recapture as much as possible of the surplus funds the forbearance generated. (Kenney) In re Ilyev, 2022 WL 2965029 (Bankr. E.D. Va. July 26, 2022)
Stanislav Ilyev filed Chapter 13 on September 1, 2017. He was a systems administrator with a law firm, was a below-median debtor and proposed a plan that would pay only . . .
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