By The Honorable William Houston Brown (Retired)

Debtors’ attorney fees after final plan payment. Although supplemental fees awarded after the debtors had completed plan payments would be subject to discharge, that did not prevent court from approving fees as an administrative expense. The court suggested potential future practices for debtors’ counsel that might prevent discharge of such fees, including plan provisions for a small administrative reserve, filing fee applications quickly after the trustee noticed final plan payments, and plan provisions for payment of supplemental fees “outside the plan” that may not be subject to discharge.

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