The Supreme Court of the United States held that section 506(a) of the Bankruptcy Code directs the application of the replacement value standard to collateral when a Chapter 13 debtor exercises the cram down option of section 1325(a)(5)(B) in its rehabilitation plan by retaining and using the collateral over the secured creditor's objection.
Associates Commercial Corp. v. Rash, 117 S. Ct. 1879 (1997).
Dawn M. Baumholtz,
Bankruptcy - Debtor's Exercise of the Cram Down Option - Valuation Standard for Collateral in Chapter 13,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol36/iss2/8