Mortgage

Ninth Circuit Splits on Avoiding and Preserving a Lien on Exempt Property

The Ninth Circuit dissenter interpreted the statute to mean that the debtor must pay a tax lien twice if the lien was avoided and preserved.
Court: 

Chapter 7 Estate Takes Post-Petition Appreciation on Conversion from Chapter 13

Joining the ‘slight minority,’ Judge Fenimore rules that post-petition appreciation in the value of a homestead goes to the chapter 7 estate when the chapter 13 case converts.

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