Affirming the bankruptcy court, the district court found that bifurcated fees are excessive and that inadequate disclosures violated Sections 526 and 528.
Within the next year, four circuits will have ruled on a split where some lower courts pay chapter 13 trustees and others don’t when dismissal precedes confirmation.
Before confirmation, district judge says that a chapter 13 debtor is only required to turn over disposable income to a trustee, not proceeds from a post-petition sale of property.