(Used with expressed permission from the MI Bankruptcy Journal and the Steven W. Rhodes Consumer Bankruptcy Conference)By Brittani Bushman, Judicial Law Clerk to the Hon. John T. Gregg, United States Bankruptcy Court for the Western District of Michigan
B. Illustrative Decisions (Minority Approach)
The Bankruptcy Appellate Panel for the Ninth Circuit recently issued a comprehensive unpublished decision adopting the minority approach, holding that § 586(e) is unambiguous and the "plain language of § 586(e)(2) means that a standing trustee is entitled to the statutory fee . . .
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