Taxing authority that voted in favor of chapter 11 debtor's proposed plan was bound by the terms of the confirmed plan. Any objections to its treatment under the plan should have been preserved by voting against the plan and objecting to confirmation. Having failed to do so, taxing authority must abide the consequences.

Chapter 13 debtors proposed a plan that paid secured creditors first, general unsecured claims second, and priority claims under 11 U.S.C. § 507 last, and the IRS objected. The court determined that 11 U.S.C. § 1322(a)(2) requires full payment of § 507 priority claims, but does not require payment of those claims in any particular order. However, relying on § 1322(b)(1), the court ruled that unsecured claims may be treated differently, under certain circumstances, so long as the different treatment does not result in unfair discrimination. Applying the four-part test in In re Wolff, 22 B.R. 510 (9th Cir. BAP 1982), the court concluded that debtor's failure to offer a reasonable basis for the discrimination prevented them from establishing Wolff's acceptable discrimination factors. The court then suggested that concurrent payment of the IRS and other unsecured creditors, on a pro rata basis, would likely not be discriminatory under § 1322(b)(1).

Chapter 11 debtor proposed a plan providing that allowed secured claims in default would receive deferred cure and compensation payments, which debtor asserted would leave those claims unimpaired pursuant to 11 U.S.C. § 1124(2). The payments were to commence 30 days after the plan's effective date. The court questioned whether cure and compensation payments under § 1124(2) could be deferred, even if sufficient interest was added to compensate for the deferral. The court considered two approaches to determining impairment, which were (1) strict construction of § 1124(1) and (2), such that a plan that alters rights in any way not expressly permitted by those provisions is considered an impairment; and (2) scrutinizing the protections offered by § 1129(b) to determine impairment only as necessary to prevent wrongs. The court found that debtor's plan left the secured claims "impaired" under both approaches, and held that cure and compensation payments must be completed by the effective date of the plan to avoid impairment.

Shortly before filing his chapter 13 petition, debtor and plaintiff entered into a contract in which debtor agreed to serve as plaintiff's sales manager as an independent contractor. Plaintiff filed an adversary proceeding in debtor's bankruptcy asserting various claims arising out of their contract. Debtor moved to dismiss, claiming lack of subject matter jurisdiction. In the alternative, debtor requested that the court abstain from hearing the dispute. The court ruled that resolution of the jurisdiction issue was unnecessary because abstention was appropriate, as debtor had already made the final payment on his plan. Since the outcome of plaintiff's claims would therefore have no effect on the administration of debtor's plan, the motion to dismiss was granted.