(United States Ninth Circuit) - In a bankruptcy case that was converted to Chapter 13 from Chapter 7,the bankruptcy court's judgment is affirmed where: 1) a creditor's claims were not subordinated because the creditor's claims did not occur out of a purchase or sale of securities, but rather were based upon a judgment entered against the debtors on account of their actions in fraudulently converting the creditor's stock; and 2) the bankruptcy court did not clearly err when it found bad faith and did not abuse its discretion when it converted debtors' Chapter 13 bankruptcy proceedings to Chapter 7 proceedings.
Source: findlaw.com