As reported by Robin Miller of CBAR, an Illinois Chapter 13 debtor could not modify confirmed plan on basis of information known prior to confirmation, to wit:
Where the debtor proposed a Chapter 13 plan that provided for full payment of an unsecured priority claim of $11,432 held by the IRS; the IRS subsequently (but prior to plan confirmation) filed a proof of claim for the lesser amount of $10,024; and the debtor’s plan as originally proposed was confirmed, the debtor could not, four months later, modify her plan, on the basis of the lesser amount of the IRS claim, so as to reduce the plan term from 60 to 55 months, as the debtor and her counsel were clearly aware of the amount the IRS was claiming as an unsecured priority claim prior to confirmation of the debtor’s original plan.
In re Moreau, 2014 WL 347045 (Bankr. C.D. Ill., Jan. 30, 2014)
(case no. 2:13-bk-90863) (Bankruptcy Judge Gerald D. Fines)