According to this, There are eligibility criteria for Fresh Start accounting.
Fresh start accounting criteria must be satisfied before the approach can be used:
Immediately prior to confirmation of the company's plan of reorganization, the company must be "balance sheet insolvent" - that is, the reorganization value of its assets is less than the sum of its post-petition liabilities and allowed claims; and The holders of the voting shares immediately before confirmation of the plan receive less than 50 percent of the voting shares of the emerging entity.