In other words, the limitations period should begin when an event occurs that has the same effect as the denial of discharge. Events which have been held to have the same effect as denial of discharge include the voluntary dismissal of bankruptcy proceedings, the waiver of discharge, and the failure to file timely for discharge. In our view, CAL's choice to convert from Chapter 11 to Chapter 7 operated like a waiver of discharge, making discharge impossible. Thus, the government had until December 1992 to file an indictment for the concealment of CAL's assets. The indictment in this case was not filed until July 1996.
Defendant disputes that an interest existed in Robinson Island.
For our purposes, we can assume that such an interest did exist.