Among the various forms of bankruptcy cases, those under Chapter 7 are sometimes characterized as the most static, with debtors’ and creditors’ rights and obligations set as of the time the petition for relief is filed. By contrast, cases under Chapter 11 and Chapter 13 are more fluid and forward-looking. Their resolution is dependent upon future events. As a consequence, they are vulnerable to intervening events and so must be capable of accommodating change.

The Bankruptcy Code acknowledges this inherent fluidity. In cases under Chapter 13, a debtor proposes a plan, which a court subsequently confirms, and the debtor then begins making distributions to creditors under the terms of that plan. Section 1329 of the Bankruptcy Code, however, acknowledges the fluidity of this process, providing, in pertinent part:

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