The Fate of Structured Dismissals in Chapter 11 Bankruptcy Cases

Bankruptcy Exit Strategies in Chapter 11 Bankruptcy Cases Following the Decision of the Supreme Court in Jevic

Business bankruptcy lawyers carefully watched the case of Czyzewski v.  Jevic Holding Corp. as it wended its way from a bankruptcy court in Delaware, through the Court of Appeals for the Third Circuit and on to the Supreme Court.  At issue in the case was whether a bankruptcy court could enter a dismissal order that provides for distributions in defiance of the priority provisions of the Bankruptcy Code without the consent of affected creditors.  Justice Breyer, writing for the majority, explained that the Court’ simple answer to this complicated question is “no.” Czyzewski v. Jevic Holding Corp., 580 U.S. ____, No 15-649, slip op. at 11 (Mar. 22, 2017).

Our simple answer to this complicated question is “no.”

Justice Breyer on Chapter 11 Bankruptcy Structured DismissalsNotwithstanding the clarity and simplicity of that answer, the holding of Jevic does not spell the end of structured dismissals or even structured dismissals that depart from the priorities accorded to creditors under the Bankruptcy Code. Rather, Jevic prohibits only orders dismissing chapter 11 cases which provide for a distribution that departs from the priorities set out in the Bankruptcy Code without the consent of the side-stepped creditors with impaired claims.

The Court found important that the two other paths for resolution of a chapter 11 bankruptcy case, plan confirmation or conversion, expressly prohibit courts from circumventing the waterfall of claim priorities.  The absolute priority rule in section 1129(b)(2) prohibits cramdown of a chapter 11 plan upon impaired creditors if the holders of junior claims or interests are to receive anything under the plan.  In a case converted to a case under chapter 7, the trustee is charged with distributing property in keeping with the priority provisions of the Bankruptcy Code.  Section 726 tracks the absolute priority rule scheme set out for cases under chapter 11.

Structured Dismissal Orders in Chapter 11 Bankruptcy Cases After Jevic

We expect that many bankruptcy courts will be inclined to read Jevic narrowly and apply its bar only to those cases where parties seek structured dismissal orders that dishonor the waterfall arrangement of priority of distributions in bankruptcy cases when the adversely affected creditors object to that treatment.  We are certain that, irrespective of how structured dismissal jurisprudence may develop after the Jevic case, business bankruptcy lawyers will continue to press the envelope in terms of creative resolutions in commercial bankruptcies.

 

How Will Bankruptcy Affect My Credit?

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Importance of Credit.

Effect of Bankruptcy on Credit

Understand the impact that filing a bankruptcy case could have on your credit score.  You may be surprised.

Understanding the Interplay Between Your Credit Score and Filing a Bankruptcy Case.

Generally, individuals considering the to file a voluntary bankruptcy petition already have at least some issues with their credit.  Pittsburgh bankruptcy lawyers generally discuss those credit issues during a free initial consultation with their clients.  Especially when it comes to chapter 7 bankruptcy cases, individuals typically consider filing to escape a dire financial situation.  Even consumers who pay their minimum payments on time may have poor credit scores because of very high debt to income ratios.  Often the maxed-out credit cards are accompanied by several late payments.  Worse, many consumers give up on even the minimum credit card payments but still remain reluctant to file a bankruptcy case.

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Filing a Bankruptcy Case Might Actually Improve Your Credit.

The filing of a bankruptcy case is an adverse credit event which, in isolation, might appear to result in a reduction to your credit score.  However, continued default on credit facilities, non-reduction of debt and no exercise of credit could be worse than taking the affirmative step a bankruptcy case to address your financial issues.  A bankruptcy case could be the quickest way to correct a badly skewed debt to income ratio.  Your credit score might also be dramatically improved when certain of your creditors’ claims are retired.  Because there are rarely quick-fixes for credit issues, it is often helpful to consider how your financial condition might change within the next 24 months.

If you’re waiting to find out how your credit score might change after a bankruptcy case, you owe it to yourself to have a free initial consultation with an experienced Pittsburgh bankruptcy lawyer.

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Refusing to File Bankruptcy Could Delay Your Fresh Start.

For consumer debtors, chapter 7 bankruptcy usually means a fresh start after getting a discharge.  The chapter 7 process moves quite quickly in comparison to the timeline of a chapter 13 case.   In chapter 13, debtors  pay a portion of what they owe to their creditors over a period of three to five years.  It doesn’t take long for debtors find that the chapter 13 plan period is not a prison sentence.  When a chapter 13 plan is confirmed it strikes a new deal between a debtor and her creditors.  At the successful conclusion of that chapter 13 plan, debtors are rewarded with a completion discharge (in fact, the chapter 13 discharge is actually more broad than the quick chapter 7 discharge ).

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A Pittsburgh Bankruptcy Lawyer Can Help You Establish Your Path Forward.

For many people in financial distress, the path outward is not entirely clear.  People are sometimes overcome by the weight of their then-present conditions and can’t see forward to a reasonable future as careful stewards of their own assets.  In other cases, people financially incapable of caring for themselves could overcommit to their responsibilities.  For a true idea of of your financial future, please contact us for a free initial consultation.

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We are a debt relief agency.  We help people file for relief under the United States Bankruptcy Code.  We are proud to have continuously expanded our clients, reach and success rate.   Please contact us if you have a challenging bankruptcy or commercial law concern.  We are excited to review your condition with you.

 

Will the President Elect’s Experiences in Bankruptcy Court Help to Expand Access to Bankruptcy for Consumer Debtors in Pittsburgh?

donald-j-trump-1271634_960_720A Pittsburgh Bankruptcy Lawyer Considers Whether a New President Might Stir Changes in Bankruptcy Law

When Donald Trump takes the oath of office, he will not be the first executive to have resorted to our nation’s bankruptcy law. Some of our most venerable Presidents have been debtors in bankruptcy cases including Thomas Jefferson, James Monroe and Abraham Lincoln. However, the shape of bankruptcy law has changed dramatically since the days of Lincoln. In fact, the United States Bankruptcy Code underwent a very dramatic overhaul in 2005 with its modification through the Bankruptcy Abuse Prevention and Consumer Protection Act (BAPCPA).

BAPCPA set in place certain restrictions for consumer debtors seeking a fresh start. Such debtors are required to undergo a course in credit counseling prior to filing a voluntary bankruptcy petition. The course must be administered by an approved agency and may vary in cost from approximately $15 to $25. The credit counseling course can generally be completed in-person or by telephone but many people find it most convenient to complete the course online. Once the course is completed, the approved counseling provider will generate a certificate of completion which it will direct to the bankruptcy lawyer for filing on the first day of the bankruptcy case.   In certain rare instances, debtors may file their bankruptcy case without completing the course and then submit a certificate of exigent circumstances which could excuse tardy compliance with the pre-petition credit counseling rule.

BAPCPA also brought with it a means test that sometimes creates a rebuttable presumption of abuse when debtors in cases under chapter 7 have monthly income in excess of relevant median income for their state. Often in those cases, the Office of the United States Trustee will issue an inquiry letter upon such debtors or their counsel requesting support for the determination that a particular chapter 7 filing is not abusive.

As a matter of policy, the present design of the Bankruptcy Code encourages filing cases under chapter 13 rather than chapter 7. Through chapter 13 bankruptcy cases, debtors may pay some or all of their debts over a period of three to five years. A chapter 13 “reorganization” bankruptcy has some special attributes and it may often present a more favorable outcome for people in certain financial positions. For instance, chapter 13 may offer the best hope for a person attempting to save their home from foreclosure.

The Bankruptcy Code also places strict restrictions upon debtors’ eligibility to for a discharge for a period of time after having received a bankruptcy discharge in a prior case. The law also severely limits the applicability of a bankruptcy discharge to student loan obligations and to many kinds of tax claims. If the political appetite to expand debtors’ rights existed, even very modest adjustments to the Bankruptcy Code could result in substantial relief for many consumers.

Whether the President Elect’s bankruptcy experience will affect the development of our nation’s bankruptcy laws is not clear. A less polarized Congress could be better positioned to pass new legislation. Moreover, filing the many judicial vacancies of the United States Courts will affect how the law is interpreted—not least when at least one of those appointments will be to the United States Supreme Court. For the time being, Pittsburgh bankruptcy lawyers will anxiously monitor the development of bankruptcy law.

We are a debt relief agency.  We help people file for relief under the United States Bankruptcy Code.

Bankruptcy Rights upon Moving to a New State

How Moving to Another State May Affect Your Bankruptcy Casebankruptcy-moving

People considering filing a bankruptcy case who have recently moved to another state or are planning an out of state move may need to address special considerations during the bankruptcy planning process.   Out-of-state moves can affect bankruptcy filings in at least two major ways:  the venue in which debtors may file their bankruptcy cases and the law governing how much property those debtors can keep out of the reach of their creditors.

On the question of venue, there are two factors that determine where a debtor may file a bankruptcy case.  Jurisdiction for a bankruptcy case may validly hinge upon the location of any of debtors’ domicile, residence, principal place of business or principal assets in the United States.  That’s the reason why so many large companies that seem to have little or no connection with Delaware or New York are able to file chapter 11 bankruptcy cases in bankruptcy courts in those states.  However, the second part of the venue question is one of timing.  If the relevant location was not constant for the six-month period preceding the filing of the case, jurisdiction is only appropriate in the districts where those things existed for the majority of that six-month period (or, if there were more than two jurisdictions, the one where those things were for the longest portion of that 180-day period).  For many debtors in cases under chapter 7 and chapter 13, the practical impact is often that they must have lived somewhere for longer than three months before they are able to file a bankruptcy case their new home state.

Exemption rights are the legal rights available to debtors under the Bankruptcy Code to shield property from their creditors. The nature of those substantive rights depends on the debtors’ residence.  Congress left it to the individual states to determine whether a state’s residents could chose between the federal or state exemption schemes or were limited to either the state or federal exemptions.  Debtors are entitled to the exemption law of the state in which they have been domiciled for the two-year period preceding the filing of their bankruptcy cases.  However, if a debtor has not lived in one state for the entirety of that two-year period, the debtor’s exemptions will be determined according to the law of the state in which his or her domicile was located for the majority of the six-month period preceding the two-year period before the case was filed (whew!).

In most instances, Pennsylvania residents who file consumer bankruptcy cases can chose between the state and federal exemptions. The election of an exemption scheme is an important and consequential decision. An experienced bankruptcy lawyer can help with that selection in order to maximize your exemptions rights.

For a free initial consultation with a Pittsburgh bankruptcy attorney, contact Robleto Law, PLLC.

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We are a debt relief agency. We help people file for relief under the United States Bankruptcy Code.

 

Bankruptcy and the Automatic Stay

The Automatic Stay – What it is and How it Can Help You Protect Your Assets

bankruptcy staySection 362 of the Bankruptcy Code provides one of the most important protections extended to debtors in bankruptcy cases. With certain exceptions, the automatic stay applies the moment a bankruptcy case is filed and prevents the commencement or continuation of adverse litigation or collection activity. For individuals attempting to stave off a scheduled sheriff’s sale of their home or avoid the repossession of a vehicle, the automatic stay is federal law strictly prohibiting foreclosures and repossessions in most instances.

Tell your bankruptcy attorney of any existing or potential lawsuits against you and all possible adverse creditor actions. Generally, it is advisable for your lawyer to immediately give notice of the bankruptcy filing to such creditors to advise them that your assets are shielded by the automatic stay.

Creditors who knowingly violate the automatic stay are subject to mandatory sanctions for your actual damages arising from the violation. Additionally, courts may award punitive damages and attorneys’ fees for such willful violations. In the event of a stay violation, your bankruptcy attorney can best advise you on how to respond.

Creditors wishing to protect their interests may file certain motions before the bankruptcy court. Commonly, creditors file motions for relief from the automatic stay so that they can continue their collection efforts. Your lawyer can discuss your goals with you and help you decide whether to defend a motion for relief from stay. Additionally, certain secured creditors may move for adequate protection payments and demand that debtors provide evidence of insurance. When those kinds of motions arise, your bankruptcy professionals will be available to help you respond.

The automatic stay provides debtors in bankruptcy cases breathing room and puts a halt to chaotic creditor collection efforts. That stay may enable debtors to confirm a plan of reorganization, cure outstanding payments or provide for an orderly turnover of an asset. To assess your goals and map a path toward a fresh start and financial freedom, contact us today for a free initial consultation.

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Saving Your Home With Chapter 13 Bankruptcy

Chapter 13 bankruptcy puts a stop to foreclosureConsumer Reorganization Through Chapter 13

If you are behind on your mortgage payments, filing a chapter 13 bankruptcy may help you avoid foreclosure.  If you are behind on payments to the point where a foreclosure complaint has already been filed by your lender, filing a bankruptcy case will immediately halt it.  The moment a bankruptcy case is filed, something called the automatic stay is put into effect.  The automatic stay is a powerful provision of the Bankruptcy Code which prevents any creditor or party-in-interest from continuing litigation against you or depriving you of your property.

Chapter 13 bankruptcy also helps you repay your past due mortgage payments.  Often, once you are several months behind on mortgage payments, you lender may refuse to accept any payment less than the total amount of the arrearages plus penalties and interest as payment, and consider the payment of a single mortgage payment a partial payment.  This perpetuates the vicious cycle.  A chapter 13 bankruptcy case allows you to pay off any arrearages over a three or five year time period – making catching up far more manageable.  Often times, chapter 13 bankruptcy is the only practical option for those substantially behind on their mortgage payments.

There are other solutions for debtors with no other problematic and significant debt beyond mortgage arrearages.  Mortgage modification, an arrangement to mitigate the lender’s loss and lower your monthly mortgage payments, can serve as a solution as well.  Modification is a negotiation and loan restructuring process which back loads your mortgage arrearages and sometimes (though not always) lowers your monthly mortgage payment.  This process often extends the term of your loan allowing your even greater advantages than might otherwise be available in a chapter 13 case limited to five years.

If you are behind on your mortgage payments and have mortgage arrearages  in excess of what you can pay back, give us a call for a free consultation to discuss a solution based on your individual goals and problems with debt.

Bankruptcy Attorney or Mortgage Modification Attorney? Maybe Both.

foreclosureBankruptcy | Mortgage Modification | Loss Mitigation 

Bankruptcy is an option for consumer debtors who have fallen behind on their mortgage payments.  If your lender has initiated a foreclosure action or has requested that you short-sell your property or execute a deed-in-lieu of foreclosure, you may wish to consider other options that will permit you to remain in your home.

Most lenders offer loss mitigation or modification options.  Borrowers who qualify for mortgage modification may see their interest rates lowered, principal balances reduced or mortgage term extended so that the monthly payments become more manageable.  In some instances, lenders may be willing to recapitalize mortgage arrearages, rather than requiring the borrower to make a lump sum, cure payment.  Mortgage modification applications are highly structured and lenders typically will not render any decision without a package that is 100% complete with current versions of all documents requested.  While many borrowers attempt to modify their mortgage without the assistance of a lawyer, an attorney who practices in the area can be very effective.

Many courts, including the United States Bankruptcy Court for the Western District of Pennsylvania, sponsor their own loss mitigation programs.  Court sponsored programs have the advantage of a judge with the power to compel mortgagees to designate a single point of contact and to come to a timely decision when the modification application is completed.

A chapter 13 bankruptcy case is also a highly effective way to preserve an at-risk interest in real property.  Unlike chapter 7 bankruptcy, bankruptcy under chapter 13 of the United States Bankruptcy Code allows debtors with a regular source of income to repay their creditors some or all of what they are owed over a period of three to five years.  For debtors who have reasonable mortgage terms but who have fallen behind on their mortgage obligation and just need some time and space to catch up, a chapter 13 filing may be the answer.  When a debtor needs both time and better mortgage terms, a chapter 13 case, together with participation in a loss mitigation program might represent that debtor’s best opportunity to save their home and get a fresh start.

Behind on a mortgage obligation?  Don’t wait until your lender forecloses on you—get a free consultation with an experienced bankruptcy lawyer today.

 Robleto Law, PLLC

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© 2014 Robleto Law, PLLC | Pittsburgh Bankruptcy Lawyers

Does Using Your Tax Return for a Bankruptcy Case Make Sense

How Applying Your Tax Return to a Bankruptcy Case Could be a Prudent Financial Planning Strategy

 

Tax Refund for Bankruptcy

Bankruptcy and Your Tax Refund

For many trapped in the cycle of credit card use and minimum payments, the question of how to use a tax refund is not a simple one.  Having access to cash is appealing.  In the short term, a tax refund may allow you to buy groceries without a credit card as well as make payments on your credit card balances.  On the other hand, you could also apply your tax returns to your credit cards and begin to chip away at your credit card debt.  The first path is almost never a sound one.  A tax refund is a once per year occurrence–the money will soon be gone but your credit card debt will remain.  Applying your tax refund to your credit card debt might make sense in some situations but, for many unfortunate people, that use of a tax refund would benefit creditors while providing no .  Let’s consider a couple of hypothetical situations.

“If your credit is already poor, filing a bankruptcy case can put you on the quickest path to rebuilding your credit”

First, let’s assume that you owe $5,000 in credit card debt with no other significant unsecured debt and you are current on all of your debt obligations.  If you receive a tax refund of $3,000 and you exercise the discipline required to plunk all of that down on your credit card obligations.  The result here could be good.  Your debt to income ratio will improve and you will be better situated to pay down the credit card debt over the coming months.

Second, let’s assume that you owe $15,000 in credit card debt and another $10,000 in unpaid medical bills.  You are consistently behind on your credit card bills and are routinely penalized with late fees and interest charges.  The same $3,000 refund will not put you in a better position to address your debts–rather it is something like dropping a teaspoon of water upon a raging fire.  Your financial position and credit score were poor prior to your receiving your tax return and will not be substantially improved by handing your tax return to your creditors.  Moreover, just as in the prior example, spending your refund on day to day living expenses offers no hope of long term improvement in your financial position.

Thus, in the first hypothetical, paying down debt with your tax refund is sensible.  In the second, it is not.

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Tax Return and Bankruptcy – A Viable Solution

The debtor in our second hypothetical, with $25,000 of unsecured debt and a $3,000 tax return could be better served by filing a chapter 7 bankruptcy case.  A case under chapter 7 of the United States Bankruptcy Code would allow that debtor to get a fresh start.  Most consumer chapter 7 bankruptcy cases last a few months and debtors never see the inside of a court room (rather, they simply meet with a trustee at a meeting of creditors that lasts only minutes).   While certain types of debt are not dischargeable (e.g., student loans, domestic support obligations and some tax obligations and criminal fines), most common unsecured debt (like credit card debt and medical debt) is dischargeable.

By using part of the $3,000 tax return to file a chapter 7 bankruptcy case, the debtor in our second hypothetical has a drastically improved debt to income ratio and more available cash from month to month.  That newly available cash flow can serve to improve quality of life and enable the debtor to begin to accumulate savings and prepare for retirement.  While the filing of a bankruptcy case does adversely affect one’s credit score, if your credit is already poor, filing a bankruptcy case can put you on the quickest path to rebuilding your credit by responsibly paying down your debts as they become due.  Contact a Pittsburgh Bankruptcy Lawyer today to find out whether a bankruptcy case could improve your financial future.

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We are a debt relief agency, we help people file for relief under the United States Bankruptcy Code.

Pittsburgh Bankruptcy Attorney

Party-in-Interest Standing to File a Plan In a Chapter 11 Bankruptcy Case

Who May File a Plan in a Chapter 11 Bankruptcy Case

The debtor in a chapter 11 case always has standing to file a plan of reorganization.  In fact, during the “exclusivity period,” only the debtor has right to file a plan.  The exclusivity period starts out as the first 120 days after the filing of the chapter 11 bankruptcy case or, in a small business case, the first 180 days following the filing of a bankruptcy petition.  Often, debtors seek extensions of their exclusivity periods.  While the requirements and timing for such motions vary between small business cases and chapter 11 bankruptcy cases that are not designated small business cases, extensions are routinely granted when debtors are diligently working toward resolving matters in order to file a confirmable chapter 11 plan of reorganization.

Filing a Chapter 11 Bankruptcy Plan After Exclusivity Has Lapsed

When the debtor’s exclusive right to file a plan of reorganization lapses or is terminated, any “party-in-interest” can file a plan of reorganization.  The term “party-in-interest” is not defined in the Bankruptcy Code but so many courts have taken up the question that bankruptcy attorneys have a good concept of its boundaries.  As mentioned, the debtor is always a party-in-interest with standing to propose a chapter 11 plan of reorganization.  The Bankruptcy Code also confers standing upon creditors of the debtor thus, outside of the exclusivity period, creditors have standing to file chapter 11 plans of reorganization.  Interestingly, the term creditor is so broadly defined in the Bankruptcy Code that any party with a claim against a debtor is considered a creditor.  A claim includes rights to payment and equitable remedies that have not been filed or reduced to judgment.  In fact, a party remains a “creditor” of a debtor even if the debtor vigorously disputes any liability to that creditor.

But party-in-interest standing goes extends beyond the debtor and its creditors and extends to any party whose interest could conceivably be affected by the confirmation of a chapter 11 plan.  Many courts have noted that the intent of Congress was to encourage greater participation in chapter 11 cases.  Effectively, party-in-interest standing is not a limit at all but, rather, an invitation to participate–the only real limit is the bare limit imposed by Article III of the United States Constitution.

To begin with, the debtor has the right to file a plan.  If exclusivity terminates, then any party-in-interest may file a plan of reorganization in a chapter 11 bankruptcy case.  To determine whether you may propose a plan of reorganization in a chapter 11 bankruptcy case and whether becoming a plan proponent makes sense, you should consult an experienced Pittsburgh Bankruptcy Lawyer.

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I Filed a Previous Bankruptcy Case, Am I Eligible for a Bankruptcy Discharge Now?

Can I File Bankruptcy Again; The Prior Bankruptcy Case Question

past bankruptciesCan I file bankruptcy again after a prior bankruptcy case?  Many individuals who were debtors in a prior bankruptcy case and who fall upon hard times a few years later want to know whether they can file bankruptcy again.  The answer to that question very much depends on several factors including (i) the timing of the prior bankruptcy case; (ii) the chapter under which the prior bankruptcy case was filed; (iii) whether the debtor received a discharge in that prior bankruptcy case; (iv) the chapter under which the debtor wishes to file a subsequent bankruptcy case; and (v) whether or not the debtor needs or expects a discharge.

If your prior bankruptcy case was dismissed with prejudice, generally, you will be unable to file bankruptcy again for a period of 180 days.  There are many reasons why a bankruptcy court could dismiss a case with prejudice but, generally speaking, when a debtor has acted in good faith but a bankruptcy court must still dismiss a bankruptcy case, the order dismissing the case will be without prejudice to file bankruptcy again.

File Bankruptcy Again – Past Bankruptcy Filing Eligibility for a Discharge Under Chapter 7 of the Bankruptcy Code

If you have a received a prior discharge in a case under chapter 7 or a case under chapter 11 of the Bankruptcy Code, you are not eligible to receive another discharge unless 8 years have elapsed between the date upon which you filed the prior case and the date when you file bankruptcy again.  If your prior discharge occurred in a case under chapter 12 or chapter 13 of the Bankruptcy Code, the waiting period is 6 years in most cases.  However, if in your prior chapter 12 or chapter 13 bankruptcy case you paid your unsecured creditors 100% of their allowed claims, you would be eligible to file bankruptcy again and receive a discharge under chapter 7 without any waiting period.  Also, if in your prior chapter 12 or chapter 13 bankruptcy case, you paid your unsecured creditors 70% of their allowed claims, proposed that prior chapter 13 bankruptcy plan in good faith and it was your best effort, you will also not be held to the 6 year bar for a discharge in a chapter 7 bankruptcy case if you chose to file bankruptcy again.

File Bankruptcy Again – Past Bankruptcy Filing Eligibility for a Discharge Under Chapter 13 of the Bankruptcy Code

You are not entitled to receive a discharge in a case under chapter 13 of the Bankruptcy Code within 4 years of having received a discharge in a case under chapter 7 or chapter 11 of the Bankruptcy Code.  Once again, the waiting period to file bankruptcy again is less for a prior case under chapter 13 of the Bankruptcy Code.  In that instance, you are barred from receiving a discharge if you file bankruptcy again within 2 years of having received a discharge in a prior chapter 13 case.

As you can see, determining eligibility for a discharge when you’ve filed a prior bankruptcy requires careful attention to the facts of your case.  Additionally, even if you are not eligible to receive a discharge, you may still wish to file bankruptcy again for other reasons.  For example, a person who has fallen behind on their mortgage payments may wish to file a chapter 13 bankruptcy case for the benefit of the automatic stay and to have the ability to repay the arrearages through a chapter 13 plan over a period of 3 to 5 years.  As with most bankruptcy questions, it is best to discuss them with an experienced bankruptcy lawyer during a free initial consultation.

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Take advantage of your free opportunity for an initial debt relief consultation.  Find out whether you qualify for relief under the United States Bankruptcy Code.  In Pittsburgh, call today for your no fee initial discussion with a highly experienced bankruptcy attorney.

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