From the Editor’s Desk - Administrative Expenses • NACTT Academy

From the Editor’s Desk – Administrative Expenses

By The Honorable William Houston Brown (Retired)

Attorney fees on preconfirmation dismissal. The Chapter 13 trustee advised debtor’s attorney of change in procedure, under which trustee would not remit undistributed funds to debtor’s attorney on dismissal of case prior to confirmation, unless attorney complied with procedure for approval of administrative expenses. The court held that the debtor’s attorney must comply with Code and Rule procedures to have fees approved, including §§ 330(a)(4)(B), 1326(a)(2), 503(b), and Rule 2016(a). Section 1326(a)(2) provides that on dismissal of the . . .

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