A hybrid contract covering both goods and services is accorded priority status under Section 503(b)(9) only for the value of the goods, even if the contract primarily involved the sale of goods.
The Tenth Circuit left an unanswered question: Do debtors retain post-filing appreciation in a home that is not sold before the case converts from chapter 13 to chapter 7?
Courts are split when it comes to deciding whether the confirmation date or the filing date should be used to value a secured lender’s collateral in cramdown.
Judge Jacobvitz told counsel for chapter 13 debtors how to write their engagement agreements to ensure being paid from funds held by the trustee if the case converts to chapter 7 before confirmation.