In In re Sanders, No. 08-1201 (6^th Cir. 12/29/2008), the Sixth Circuit addressed the requirement in 11 U.S.C. § 1328(f)(1) that a debtor wait four years before initiating a Chapter 13 proceeding after having received a Chapter 7 discharge, finding that the four-year period begins to run at the time of filing the Chapter 7 action rather than from the date of the issuance of the discharge.  Acknowledging that its reading of the statute created certain complications with respect to § 1328(f)(2), which limits the filing of consecutive Chapter 13 cases, the court declined to attempt to unravel Congress’ intent, and instead relied on the plain grammatical meaning of the language of the statute.