In re Evans: Disgorging Chapter 13 Trustee Fees in Cases Dismissed Prior to Confirmation

By Jen Grondahl Lee, Jen Lee Law, Inc. (San Ramon, CA)

When is a collected fee not a collected fee? When the statutes authorizing payment to the standing Chapter 13 trustee do not provide clear guidance on when that fee is paid and/or earned. The most recent case on this issue is In re Evans (Bankr. Idaho 2020).1

In a Memorandum of Decision entered February 13, 2020 in the United States Bankruptcy Court for the District of Idaho . . .

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