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Bankruptcy Court for Illinois Ruled On Subchapter V Plan Case

The National Tractor Parts holding establishes that substantial consummation even if distributions are de minimis locks in a consensual plan and prevents post-confirmation plan modification by subchapter V debtors. But this holding does not extend to non-consensual plans
United States National Tractor Parts Inc Dean Hardwoods Inc Illinois Bankruptcy Court Small Business Administration Bankruptcy Court Decision

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