Just when courts appeared to be developing a consensus on how to value affordable housing projects in bankruptcy, an opinion from the 9th Circuit Court of Appeals has muddied the landscape. In In re Sunnyslope Housing Ltd. Partnership , a divided panel of the 9th Circuit Court of Appeals recently held that rent restrictions should not be considered when valuing a secured creditor's interest in an affordable housing project that the debtor proposes to retain under a plan of reorganization .

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