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§ 706

Swartz, In re

Ruling
Court approved Chapter 13 conversion as credible lower home appraisal and debtors’ good faith would prevent prejudice to creditors and preserve equity. (Bankr. E.D. Pa.)
Issue(s)
Conversion.

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Consumer opinion summary, case decided on June 30, 2025 , LexisNexis #0925-039

Conway, In re

Ruling
Conversion to Chapter 13 denied as debtors acted in bad faith and lacked feasible plan to repay creditors. (Bankr. W.D. Wis.)
Issue(s)
Conversion.

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Consumer opinion summary, case decided on May 09, 2025 , LexisNexis #0725-044

Nadeau, In re

Ruling
Chapter 7 discharge did not automatically preclude conversion to Chapter 13 as debtor would need to propose and complete a confirmable plan. (Bankr. N.D. Ohio)
Issue(s)
Conversion.

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Consumer opinion summary, case decided on May 06, 2025 , LexisNexis #0725-043

Ali, In re

Ruling
Conversion from Chapter 7 to Chapter 13 denied as debtor failed to establish proposed third party contributions were sufficiently stable and regular to enable her to fund the 100% repayment plan. (Bankr. E.D.N.Y.)
Issue(s)
Conversion.

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Consumer opinion summary, case decided on December 26, 2024 , LexisNexis #0325-010

Zarifian Enters., LLC, In re

Ruling
Debtor's motion to convert Chapter 7 case to Chapter 11 Subchapter V granted as winding down a business and liquidating assets to pay creditors qualifies as being engaged in commercial or business activities. (Bankr. N.D. Ill.)
Issue(s)
Conversion; By the Debtor.

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Commercial opinion summary, case decided on December 17, 2024 , LexisNexis #0325-011

Shelby, In re

Ruling
Court concluded that a Chapter 7 debtor who has received a discharge may convert to Chapter 13 but the discharge should be set aside upon conversion. (Bankr. E.D. Mo.)
Issue(s)
Conversion; By the Debtor.

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Consumer opinion summary, case decided on September 04, 2024 , LexisNexis #1124-039

Autry, In re

Ruling
Debtors were not entitled to convert their case to Chapter 13 as they acted in bad faith in their Chapter 7 case. (Bankr. M.D.N.C.)
Issue(s)
Conversion.

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Consumer opinion summary, case decided on August 15, 2024 , LexisNexis #1124-064

Gonzalez, In re--Avery v. Gonzalez

Ruling
Motion to convert Chapter 7 case to Chapter 13 deprived the Chapter 7 trustee of control over the bankruptcy estate. (Bankr. C.D. Cal.)
Issue(s)
Conversion; By the Debtor.

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Consumer opinion summary, case decided on May 26, 2023 , LexisNexis #0723-063

United Furniture Indus., In re

Ruling
Debtor's business decision to cease operations did not constitute bad faith and there was noshowing that its actions or inactions were fraudulent. (Bankr. N.D. Miss.)
Issue(s)
Conversion; By the Debtor.

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Commercial opinion summary, case decided on January 27, 2023 , LexisNexis #0323-091

Alcantar, In re

Ruling
Debtor's motion to convert from Chapter 7 to Chapter 13 was denied because the debtor couldnot qualify for conversion unless the discharge order was vacated. (Bankr. N.D. Ill.)
Issue(s)
Conversion; By the Debtor.

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Consumer opinion summary, case decided on September 10, 2021 , LexisNexis #1021-094