In another bankruptcy case decided this past term, the United States Supreme Court held that Section 506(d) of the Bankruptcy Code cannot be used by a Chapter 7 debtor to "strip down" the unsecured portion of a lien. Bank of America v. Caulkett, 575 US__ , 135 S. Ct. 1995 (2015)
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See AllIn Sunnyslope Housing LTD. Partnership, an en banc court was presented with an unusual fact pattern when a creditor objected to the...
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