Making Sense of the Cause Requirement for Plan Payment Period Extensions Under 11 U.S.C. § 1322(d) – Part 2 of 2

Warner continues and concludes his deep dive into plan extensions looking at (1) whether or not to extend is a case specific inquiry; (2) the Walsh court vs. acceptable judicial intervention; and (3) moral obligation as a basis for plan payment extensions.

Unlock This Article

To get started, please let us know which of these best fits your current position:

Please sign in to continue reading this content.
Screenshot_9-6-2025_113116_
Law Clerk to Jack N. Zaharopoulos, Office of the Chapter 13 Trustee for the Middle District of Pennsylvania (Hummelstown)

Blake Warner is a 2nd year law student at Penn State Dickinson School of Law.

Related Articles

November 15, 2020
Lawrence R. Ahern, III Brown & Ahern Nashville, Tennessee Appendix C Bankruptcy Court Miscellaneous Fee Schedule (28 U.S.C § 1930) Effective December 1, 2020 Description Current Fee Adjusted Fee Exemplification $22 $23 Reproduction of audio recording of court proceeding $31 $32 Filing amendment to debtor's schedules $31 $32 Search fee $31 $32 Filing any document that is not related to...
Members
boltz2
March 15, 2026
This is one of Ed’s best. The study is meaningful, but Ed’s commentary hits all the nails on their heads. This item is not password protected.
March 24, 2019
By Wm. Houston Brown, United States Bankruptcy Judge (Retired) Discharge - Direct mortgage payments unpaid by debtor were not “provided for” in plan. The confirmed plan stated that the debtor would directly pay two home mortgages to the credit union, but there was no specification of payment terms or other treatment of those mortgages. At the time of confirmation, the...
Members
June 9, 2019
By Jan Hamilton, Chapter 13 Trustee (Topeka, KS) Introduction Preliminarily, I recognize that many of those reading this do not need to. There are many fine trial attorneys in the bankruptcy bar. Those folks could well be writing this article. By way of defending myself in advance, this little piece does not consist of a series of war stories or...
Members
regina26
January 11, 2026
On November 24, 2025, the United States Postal Service quietly revised its policy on when mail is postmarked — a change that could have big implications for anyone who relies on postmarks to prove they mailed something on a specific date.
Members
moran_cathy
August 20, 2023
What are the consequences of a secured lender’s failure to comply with R. 3002.1 in a prior case when the debtor files again? Significant, it seems. . . . since their attorney said he “didn’t see the need” to do so. [Can you guess, now, how this comes out?]
Members
Copy of Hildebrand-2016
Chapter 13 plan proposing to pay nondischargeable student loans under § 1325(b)(5) cannot be confirmed unless the plan proposes to devote all disposable income to the plan or all unsecured claims (including the student loans) are paid in full.
Members
Copy of Hildebrand-2016
October 8, 2023
Chapter 13 debtor that repeatedly fails to maintain payments to the mortgage servicer directly as provided in the original plan and in all amendments is not acting in good faith and has misled the court as to feasibility of the plan justifying dismissal of the case.
Members
NBR cropped 2
May 14, 2023
Dear Readers: Want to know why your 1L Civ Pro course is your best friend when it comes to “undue hardship” cases?  Because burdens of proof matter.  (They matter in other cases, too, but I’m in love with the case of Love v. U.S. Dept. of Education (In re Love), Case No. 19-20532-C-7, United States Bankruptcy Court for the Eastern...
Members

Looking to Become a Member?

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.

Webinars

These informative sessions are led by industry experts and cover a range of consumer bankruptcy topics.

Member Articles

Written by industry experts, these articles provide in-depth analysis and practical guidance on consumer bankruptcy topics.

Industry News

The Academy is the go-to source for the latest news and analysis in the Chapter 13 bankruptcy industry.

To get started, please let us know which of these best fits your current position: