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Tenth Circuit: Debtors Retain Appreciation in a Home Sold Before Conversion to ‘7’

The Tenth Circuit left an unanswered question: Do debtors retain post-filing appreciation in a home that is not sold before the case converts from chapter 13 to chapter 7?
Court: 

Chapter 13 Debtor Keeps a Whopping Increase in the Value of a Home

On a question where the courts are split, a New Jersey bankruptcy judge allowed the chapter 13 debtor to retain a $100,000 increase in value when he sold his home.

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