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Chapter 13 Trustees Are Paid Even if Dismissal Comes Before Confirmation, BAP Says

The Ninth Circuit BAP joins the minority on an issue that’s headed for the court of appeals.
Court: 

Chapter 12 Farmer Plan May Pay Impaired Secured Creditors Directly

The lender’s consent to direct payments by the family farmer persuaded Judge Furay to overrule the chapter 12 trustee’s objection to the plan.

Courts Split on Paying Chapter 13 Trustee Fees in Cases Dismissed Before Confirmation

Long Island judge finds no ambiguity in two statutes that other courts have found ambiguous when read together.

No Fees for a Chapter 13 Trustee in a Case Dismissed Before Confirmation

Trustees in chapter 12 fare better than chapter 13 trustees if a case is dismissed before confirmation.
Court: