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Tenth Circuit Doesn’t Pay ‘13’ Trustee if Dismissal Precedes Confirmation

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.
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District Court Says Chapter 13 Trustee Is Paid Even if Dismissal Precedes 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.
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