Case Summary:
Chapter 13 plan modification. The Debtor’s ex-attorney sought to modify the Chapter 13 plan to extend payments and pay attorney’s fees. In the Seventh Circuit, § 1329 imposes no threshold requirement of a change in financial circumstances. The attorney was the “holder of an allowed unsecured claim,” thus he could seek modification to “extend . . . time for such payments.” § 1329(a). Modification of the plan was approved.

Statute/Rule References:
11 U.S.C. § 1329(a) -- Modification of Plan After Confirmation

Key Terms:
Administrative Expenses