Entries by Nisha Parikh

NINTH CIRCUIT | Key Points

The Bankruptcy Appellate Panel for the Ninth Circuit recently found that assets fraudulently transferred by a debtor during his Chapter 13 bankruptcy proceedings constituted assets of the bankruptcy estate despite a forced conversion of the proceedings from Chapter 13 to Chapter 7. In re Brown, 953 F.3d 617, 618 (9th Cir. 2020). In Brown, Jason […]

NINTH CIRCUIT FINDS FUNDS FRAUDULENTLY TRANSFERRED BY DEBTOR TO BE PART OF CONVERTED CHAPTER 7 ESTATE

Earlier this year the Bankruptcy Appellate Panel for the Ninth Circuit found that assets fraudulently transferred by a debtor during his Chapter 13 bankruptcy proceedings constituted assets of the bankruptcy estate despite a forced conversion of the proceedings from Chapter 13 to Chapter 7. In re Brown. In Brown, the Court explained “[t]he problem…began when […]