In re Brumm

Pre 2005-Act: 
Pre 2005-Act
Debtor allowed to refinance appreciated property to payoff plan early without modification.
Procedural posture: 
Chapter 13 debtor filed a motion to refinance his principal residence and payoff his confirmed chapter 13 plan early. The chapter 13 trustee objected to the motion, unless the debtor was required to modify the plan's dividend to unsecured creditors from 0 percent to 100 percent.
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