Critical Case Comment

By Henry E. Hildebrand, III, Chapter 13 Standing Trustee for the Middle District of Tennessee (Nashville)

Despite a split in authority, funds held by a Chapter 13 Trustee at the time a case is dismissed prior to confirmation, are subject to the trustee’s commission before any balance is returned to the debtor. In re Doll, 17-20831-MER (Bankr. D.Colo. Feb. 19, 2021) (Romero)

Case Summary

Daniel Doll filed a Chapter 13 petition in November of 2017 but, following a heavily litigated confirmation process, the bankruptcy court refused to confirm his proposed plan and . . .

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