When case converts from Chapter 13 to Chapter 7, the Chapter 7 trustee is not limited to the valuation of the debtor’s home as stated on the original schedules and may capture the increase in equity resulting from the property’s appreciation. (Dales) In re Adams, 2022 WL 2079725 (Bankr. W.D. Mich. June 9, 2022)
Matthew and Katherine Adams filed a Chapter 13 petition on February 17, 2020 and the Court confirmed their plan. They had given a valuation to their home of $115,000 on their schedules. When . . .
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