How do you value a Chapter 13 debtor’s business for purposes of the best interests of creditors test?

In a recent Michigan bankruptcy court decision, the court used the “going concern forced sale value” to value Chapter 13 debtor’s business for purpose of best interests of creditors test in Code § 1325(a)(4). The court was faced with determining the proper valuation methodology for the Chapter 13 debtor’s interest in a hair salon; the…

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