In re Frederickson, 545 F.3d 652 (8th Cir. 2008)

(above-median Chapter 13 debtor's plan must extend for five years; bankruptcy court erred by confirming debtor's plan as a four-year plan; court's holding is opposite the holding in In re Kagenveama, 541 F.3d 868 (9th Cir. 2008))