The following excerpt is from Sterling v. Harwood, BAP No. NC-15-1055-DTaKu (B.A.P. 9th Cir. 2016):
plan confirmation. See Law v. Siegel, 134 S.Ct. 1188, 1194 (2014) (bankruptcy court's inherent powers do not allow it to contravene express Code provisions). Thus, the bankruptcy court did not err in rejecting the unclean hands doctrine as a potential barrier to confirmation separate and distinct from the good faith requirements of 1325(a)(3) and (7).
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