Task: Wrong Candidate Generation
Input (English): is not practicable. 11 U.S.C. § 1328(b). Most courts faced with a request for a hardship discharge have required the presence of catastrophic or compelling circumstances. See, e.g., In re Bandilli, 231 B.R. 836, 838 (1st Cir. BAP 1999) (an unanticipated death precluding payments under a confirmed plan held to be a catastrophic circumstance beyond the debtor’s control to support granting a hardship discharge). These debtors have not faced death or disability. Their reasons for the modification are just chronically poor economics, and they undoubtedly still need the case to help save their home. Therefore, hardship standards do not apply. This court has always looked askance at changes to the playing field this late in the game. See In re Zakowski, 213 B.R. 1003 (Bankr.E.D.Wis.1997) (<HOLDING>). Here, the debtors moved to amend their plan 
 Holding statements: (A) holding that property seized by a creditor prior to debtors bankruptcy was property of the estate even though creditor  the irs  held a secured interest  a tax lien  in the property (B) holding it would not be fair to secured creditor to require release of its lien just a few months prior to plans completion when due to continuous negotiations throughout the pendency of the plan the bank expected to be paid in full (C) holding that by virtue of section 1325a5 holder of secured claim retains the lien until the underlying debt is paid in full (D) holding that the secured creditor was only entitled to the amount of its claim as provided in the debtors chapter 13 plan when the destruction of the vehicle yielded insurance proceeds greater than the secured creditors claim (E) holding that a secured creditor is not entitled to receive any more than that to which it was entitled pursuant to the terms of the confirmed plan
Output (English): holding that by virtue of section 1325a5 holder of secured claim retains the lien until the underlying debt is paid in full