Converting
from 13 to 7: funds held by the chapter 13 trustee are the
post-petition property of the debtor. Therefore, will
be returned to the debtor. Unless, the funds were
derived from pre-petition assets or pre-petition tax
refunds. In that case those funds will be surrender to
the chapter 7 trustee.
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all thirteen Federal Circuit Courts, the California Supreme
Court, the California Appellate Courts, and the New York Court
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