A Penny Returned Is a Penny Earned Who Gets the Money Upon Conversion of a Chapter 13 Case to Chapter 7 Before Confirmation
Under the Bankruptcy Reform Act of 1978, 1 there was a split of authority as to the disposition of funds paid to the chapter 13 trustee after commencement of a case where the case was converted to a chapter 7 case before confirmation of a plan. 2 In 1994, Congress