A ‘13’ Debtor Can’t Dismiss After Conversion to ‘7,’ Tenth Circuit BAP Says
Quick Take
A 14-day stay under Rule 7062 might have saved the chapter 13 debtor’s right to dismiss under Section 1307(b).
Being a ‘Net Winner’ in a Ponzi Scheme Doesn’t Automatically Mean Nondischargeability
Quick Take
Alleging that a debtor realized an ‘impossibly high’ rate of return in a Ponzi scheme isn’t enough to state a claim of nondischargeability for ‘actual fraud.’
Another Circuit Says Creditors Take Appreciation When a ‘13’ Case Converts to ‘7’
Quick Take
The Eighth Circuit aligned with the Ninth Circuit by holding that postpetition appreciation in a home belongs to creditors when a chapter 13 case converts to chapter 7.