Equitable tolling can extend the two-year deadline for filing complaints, but the deadline can’t be extended without notice to the defendants, even if they are unknown or unknowable.
District judge in Idaho finds no ambiguity in a statute that doesn’t explicitly say whether a chapter 13 trustee is paid if the case is dismissed before confirmation.
A trustee can avoid and preserve a tax lien for the benefit of unsecured creditors, but a debtor can’t if the debtor hasn’t paid the taxes, the Ninth Circuit says.
