September 26, 2020
In Michigan, the leading case on this subject is In re: Gonzales (Bankr. W.D. Mich. Dec. 21, 2017). Here, Judge Dales stated that “a chapter 13 trustee in possession of post-confirmation bankruptcy plan payments when the dismissal order is entered must remit them to the debtor, unless a court order provides otherwise.” In re Gonzales,
