Although a claim involving only goods sold to the debtor qualifies as an administrative expense under § 503(b)(9)[1] of the Bankruptcy Code, courts are split as to whether, and to what extent, this section covers so-called “hybrid” claims—those involving both goods and services transactions.

In the wake of the global credit crisis, the U.S. housing market plummeted with values declining as much as 50 percent and home foreclosures at record highs. With lower asset values and frozen credit markets, it became difficult, if not impossible, for U.S. homebuilders to continue business operations. Many U.S.

Creditor committees use valuation reports in a variety of ways, and it is important for the lawyer or financial advisor to help the committee understand how to read and evaluate a valuation report.

May a creditor’s claim be disallowed simply because he or she failed to provide supporting documentation in violation of Rule 3001 of the Federal Rules of Bankruptcy Procedure? The answer depends on which jurisdiction the creditor is pursuing its claim in, and courts are currently sharply divided on the issue.