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On Dismissal of a ‘13,’ Barton May (or May Not) Bar Garnishments

Section 1326(a)(2) by itself does not bar garnishment of funds held by a trustee on dismissal before confirmation.
Court: 
10th Circuit

Third Circuit Resurrects an ‘Admin’ Claim When the Stalking Horse Had No Breakup Fee

The Third Circuit found loopholes in the purchase agreement permitting the buyer to assert an administrative claim, even though the breakup fee was disallowed.
Court: 
3rd Circuit

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