In re Byrd (99-54163)

The secured status of a creditor should be determined for the purpose of Section 1325(a)(5)(B) based on collateral's confirmation date replacement value, but in a Chapter 13 case, secured status should be determined based on a value no less than the petition date liquidation value if the creditor's claim is secured by inherently depreciable collateral.

Wednesday, March 1, 2000