Below-median Chapter 13 debtor bears the burden of justifying a plan longer than three years as confirmation of a five-year plan would be denied as providing insufficient justification to exceed three years. (Robinson) In re Ingram, 2023 WL 2529730 (Bankr. N.D. Ala. March 15, 2023)
Danny Ingram filed four bankruptcy cases over 20 years. He was single with no dependents and had below-median income of $1,390 derived only from social security benefits.
Ingram proposed a five-year plan which would pay nothing to unsecured . . .
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