1325

Bankruptcy Judge Michelle Harner held that a wholly unsecured, subordinate lien may be stripped off in chapter 13 even if the lien arose before the debtor owned the property.

Courts are split on whether the confirmation requirements in Section 1325(b)(1) apply when a debtor seeks confirmation of an amended plan.

Benchnotes By Christina Sanfelippo, Aaron M. Kaufman and Bradley D. Pack Bankruptcy Courts Lack Discretion to Deny a Request to Appoint an Examiner If Requirements of § 1104(c)(2) Are Met The Third Circuit recently held that if “the debtor’s total fixed, liquidated