Critical Case Comment

By Henry E. Hildebrand, III

Bankruptcy courts have the discretion to permit debtors to cure deficiencies in their Chapter 13 plans even if in doing so, the Chapter 13 plan exceeds 60 months from the date of first payment. (Krause) In re Klaas, 858 F.3d 820 (3rd Cir. June 1, 2017)

Case Summary

Paul and Beth Ann Klaas filed their Chapter 13 petition in 2009, proposing to make payments over a 60-month period. During the pendency of the case, an adjustment was made to provide for a mortgage payment increase and the . . .

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