(Used with expressed permission from the MI Bankruptcy Journal and the Steven W. Rhodes Consumer Bankruptcy Conference)
Although the Bankruptcy Code has been around for decades, bankruptcy courts continue to be faced with significant disputes regarding the interpretation of its provisions. An emerging issue that has gained traction in recent years involves the compensation of a chapter 13 trustee upon the dismissal or conversion of a case prior to confirmation.1 This issue turns on courts' interpretation of the seemingly conflicting directives of 28 U . . .
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