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ABI Journal

1226

Tenth Circuit Doesn’t Pay ‘13’ Trustee if Dismissal Precedes Confirmation

The first court of appeals to rule on a question where lower courts are split, the Tenth Circuit finds the statute unambiguous and requires a chapter 13 trustee to disgorge his or her fee if the case is dismissed before confirmation.

District Court Says Chapter 13 Trustee Is Paid Even if Dismissal Precedes Confirmation

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.