From the Editor – Debtor’s Attorney

By The Honorable William Houston Brown (Retired)

No attorney fees for Chapter 7 work in converted case. In a case that began as Chapter 7 and converted to Chapter 13, the debtor’s attorney sought fees for work in the Chapter 7 phase under § 330(a)(4)(B) rather than § 330(a)(1). The Court found the better interpretation of § 330(a)(4)(B)’s language “in connection with the bankruptcy case” to refer to compensation in connection with the Chapter 13 phase of the converted case. “It would not make sense, on the one hand . . .

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