Case 21-30247-KLP Claim #6 Filed 03/09/21 Entered 03/09/21 09:34 Objection 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION

In re:

LAWRENCE HENDERSON THOMAS, CHAPTER 13

DEBTOR. CASE NO. 21-30247-KLP 

OBJECTION TO CONFIRMATION OF CHAPTER 13 PLAN

NOTICE

YOUR RIGHTS MAY BE AFFECTED. YOU THESE PAPERS CAREFULLY AND DISCUSS THEM WITH YOUR

ATTORNEY,IFYOU HAVE ONE IN THISBANKRUPTCYCASE. (IFYOU DO NOT HAVE AN ATTORNEY, YO U MAY

WISH TO CONSULT ONE.)

IF YOU DO NOT WISH THE COURTTO SUSTAINTHE OBJECTION SOUGHT HEREIN, OR IF YOUWANT THE COURT 

TO CONSIDERYOURVIEWSONTHEOBJECTION,THENYOU MUSTATTEND THE HEARING ON THIS MATTER, 

OTHERWISE, THE COURT MAY DEEM OPPOSITION WAIVED, TREAT THE OBJECTION AS CONCEDED, AND

ISSUE AN ORDER SUSTAININGTHE OBJECTION WITHOUT FURTHER NOTICE OR HEARING.

THE HEARING IS SCHEDULEDTO BE HELD ON March 24, 2021AT 9:10 AM AT THE 

U.S. BANKRUPTCY COURT, 701 E. BROAD ST, RM. 5100, RICHMOND, VA 23219.

COMESNOW, Chanell Gaines Thomas(“SecuredCreditor”),andobjects to the 

confirmation of the Chapter 13 Plan (the “Plan”) and in support thereof, represents unto the

Court:

1. Secured Creditor has a validly perfected Property Settlement Agreement 

related to Joint Internal Revenue Service (IRS) tax debt for Tax Year 2012, 2013, and 2014 

pursuant to a valid Property Settlement Agreement dated May 18, 2018.

2. The Proof of Claim (Claim# 6) filed on March 9, 2021 by this Secured Creditor

establishes a total debt of $5,074.39 including pre-petition interest and penalties at 3percent.

3. The Plan dramatically understates the amount owed to Secured Creditor, listing 

as $500.00 in section 3B. Secured Creditor hereby objects to any part of the Plan that 

impermissibly attempts to modify this Secured Creditor’s claim. Pursuant to Section §523 (a)

(5) of the Bankruptcy Code.

Case 21-30247-KLP Doc 19 Filed 03/10/21 Entered 03/11/21 09:54:16 Desc Main

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Case 21-30247-KLP Claim #6 Filed 03/09/21 Entered 03/09/21 09:34 Objection 

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4. The Plan does not provide the Secured Creditor with an appropriate interest 

rate based on the internal Revenue Service’s current rate of 3 percent. The Plan proposes

an interestrate of 3 percent.

Secured Creditor objects and asserts that the Plan must provide for the total amount of the claim 

and an interest rate of 3 percent.

5. Any Chapter 13 Plan proposed by the Debtor must provide for and eliminate 

the objections specified above in order to be feasible and to provide adequate protection to 

this Secured Creditor. It is respectfully requested that this Court deny confirmation of the

Plan.

WHEREFORE, the undersigned requests as follows:

1. That confirmation of the proposed Plan be denied;

2. Debtor be required to modify the Plan to honor the terms and conditions of 

the Property Settlement Agreement; and

3. For such other relief as this Court deems proper.

Chanell Gaines Thomas

By: CHANELL GAINES THOMAS

3827 Ruslander Court

Richmond, VA 23223

Tel: (804) 503-0997

queensnyangel@yahoo.com

CERTIFICATE OF SERVICE

I certify that on March 10, 2021, the foregoing Objection was served via CM/ECF on 

Carl M. Bates, Trustee, and James E. Kane, Counsel for Debtor, at the email address registered 

with the Court, and that a true copy was mailed via first class mail, postage prepaid, to Lawrence 

Henderson Thomas, Debtor, 2501 Byron Street, Richmond, VA 23223.

CHANELL GAINES THOMAS

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