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The first court of appeals to rule on a question where lower courts are split, the Tenth Circuit finds the statute unambiguous and requires a chapter 13 trustee to disgorge his or her fee if the case is dismissed before confirmation.

District judge in Idaho finds no ambiguity in a statute that doesn’t explicitly say whether a chapter 13 trustee is paid if the case is dismissed before confirmation.

District judge in Colorado sides with the majority and doesn’t allow a chapter 13 trustee to be paid if dismissal occurs before plan confirmation.