Professional Compensation/Fees

Courts Are Split on Whether Counsel Fees Are Considered in the Chapter 13 Best Interests Test

Deferred payments to unsecured creditors in a chapter 13 plan must equal the present value of the distributions required by the best interests test, Judge Halfenger says.

Contested Matters Aren’t ‘Civil Actions’ Under the Equal Access to Justice Act

A contested matter in bankruptcy court isn’t a ‘civil action’ allowing the debtor to recover attorneys’ fees from the U.S. Trustee under the Equal Access to Justice Act.

No Retroactive Adequate Protection in Chapter 13, Judge Trust Says

Long Island judge follows ‘Burt’ Lifland and rules that a secured creditor is not entitled to adequate protections for periods of time before filing a motion giving rise to adequate protection.

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.