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ABI Journal

1326

BAP Rejects Due Process Attack for Denial of ‘13’ Trustee Fees on Dismissal

Ninth Circuit BAP says there is no due process problem with denial of chapter 13 trustee fees if dismissal precedes confirmation.

On Conversion to ‘7,’ Admin Expenses in ‘13’ Must Be Paid, Harris Notwithstanding

When chapter 13 cases are converted to chapter 7 before confirmation, bankruptcy courts are split on whether the broad language in Harris v. Viegelahn bars chapter 13 trustees from paying administrative expenses incurred before conversion.