Noah G. Hillen

Idaho Nov 21, 2025

Tax Refund Turnover Isn’t Required When the ‘13’ Plan Pays Creditors in Full

Chapter 13 trustee can’t require a debtor to maintain a ‘safety net,’ Bankruptcy Judge Hillen says.
9th Circuit Idaho Jan 26, 2024

Creditors Don’t Receive Estate Assets Recovered After the Last Chapter 13 Plan Payment

Absent a provision in the plan to the contrary, creditors aren’t given estate assets recovered after the final plan payment.