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 […]
