§ 9.6.1.3 Chapters 12 and 13. Discharge in both chapter 12 and 13 cases is granted at the same time: upon completion of all payments under the plan. 11 U.S.C. §§ 1228(a), 1328(a) . A debtor also is entitled to a “hardship” discharge in a chapter 12 or 13 case if:
1. the debtor is unable to make plan payments due to circumstances for which the debtor should not be held accountable;
2. creditors have received at least as much as they would have been paid if the case were in chapter 7; and
3. modification of the plan is not practicable.
11 U.S.C. §§ 1228(b), 1328(b) .
In chapter 12, a debtor does not receive a discharge of any debt specified in § 523(a) . The discharge in chapter 13 can be...
