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Courts are split on whether chapter 7 trustees can be paid on another theory when the trustee had made no distributions to creditors under Section 326(a).
The First Circuit applied the ‘collateral order doctrine’ to allow an appeal by the government when a private party would be stuck with a nonappealable, interlocutory order.
Bankruptcy courts are divided on whether the calculation of a trustee’s commissions includes distributions made to co-owners of property that the trustee has sold.