Phillips v. White (In re White)

BRORBY, Circuit Judge.

In this case, we are called upon to decide what property is included in the bankruptcy estate upon the conversion from Chapter 12 to Chapter 7. This requires an interpretation of sections 348, 541, and 1207 of the Bankruptcy Code. We hold the proceeds earned from crops before the conversion but during the pendency of bankruptcy are part of the bankruptcy estate.

Barbara and Raymond White (the “Debtors”) are farmers who filed for relief under Chapter 12 of the Bankruptcy Code. They proposed a plan specifying “[u]pon confirmation of the plan, all of the property of the…