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§ 503(b)(1)

In re JS Mktg. & Communs. Inc.

Ruling
Administrative expense claim for postpetition rent by insider creditor denied in chapter 7 case.
Procedural posture

Individual and corporate lessors of a building filed a request for payment of administrative expenses for post-petition rent incurred by a chapter 7 debtor under the terms of an expired written lease of business premises. The trustee filed an objection.

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Commercial opinion summary, case decided on January 24, 2008 , LexisNexis #0208-112

In re Ziemann

Ruling
Postpetition state court order for debtor to pay former spouse's legal fees did not qualify as an administrative expense.
Procedural posture

Debtor moved for an order determining the priority of and clarifying the payee on an award of legal fees ordered by a state domestic relations court and modifying the chapter 11 plan of reorganization to provide for payment thereof. Objector spouse, the beneficiary of the legal fee order, argued that it was not properly characterized as an administrative claim and asked that the motion be denied.

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Consumer opinion summary, case decided on January 10, 2008 , LexisNexis #0308027

In re EZ Pay Servs.

Ruling
Administrative expense claim for fees of computer forensics expert approved.
Procedural posture

Chapter 7 trustee filed an application to pay the administrative expense claim of a computer forensics expert employed by the trustee, in the amount of $ 70,000, pursuant to 11 U.S.C.S. § 503(b)(1).

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Commercial opinion summary, case decided on September 28, 2007 , LexisNexis #0208-111

In re Scotia Dev. LLC

Ruling
Severance payments due terminated employees due to prepetition agreement were not entitled to priority.
Procedural posture

Chapter 11 debtors filed a motion for authority to pay specified benefits to certain terminated employees under 11 U.S.C. § 503(b)(1).

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Commercial opinion summary, case decided on September 21, 2007 , LexisNexis #1007-109

In re Anchor Glass Container Corp.

Ruling
Prepetition municipal tax claim did not qualify for administrative status.
Procedural posture

Before the court was the City of Warner Robins, Georgia's request for allowance of an administrative claim in the amount of $351,422 for real and personal property taxes for the year 2005 (the tax claim), and objections of debtor and trustee thereto.

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Commercial opinion summary, case decided on September 10, 2007 , LexisNexis #1007-098

In re White

Ruling
Creditor's administrative expense claim filed three years after plan confirmation disallowed.
Procedural posture

Debtors filed a petition under chapter 13, and the court confirmed their plan for repaying their creditors. Just over three years later, a creditor filed a motion for allowance of an administrative expense claim under 11 U.S.C. § 503(b)(1)(A). The chapter 13 trustee filed an objection to the creditor's motion.

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opinion summary, case decided on July 03, 2007 , LexisNexis #0807-062

In re Perry

Ruling
Landlord not entitled to administrative expense claim for postpetition rent arrears.
Procedural posture

A debtor objected to a creditor's proof of claim for rent as not entitled to priority and as overstated.

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opinion summary, case decided on May 22, 2007 , LexisNexis #0607-109

In re Fifer

Ruling
Debtor's accountant allowed administrative expense fee for preparation of six tax returns.
Procedural posture

A debtor's accountant applied for the allowance of his fees as an administrative expense, pursuant to 11 U.S.C. § 503(b)(1)(A).

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opinion summary, case decided on April 25, 2007 , LexisNexis #0607-085

In re Fortune Natural Res. Corp.

Ruling
Directors of corporate debtor were not entitled to administrative expense for postpetition services.
Procedural posture

Former directors of a corporate bankruptcy debtor continued to perform services for the debtor after its bankruptcy, and the directors asserted that they performed actual and necessary services to preserve the bankruptcy estate for the benefit of creditors. After the debtor's plan of reorganization was confirmed, the directors moved for allowance of compensation to the directors as an administrative expense under 11 U.S.C. § 503(b)(1)(A).

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opinion summary, case decided on April 12, 2007 , LexisNexis #0607-022

In re Brown

Ruling
Creditor granted administrative expense for counsel fees due to actions to preserve estate.
Procedural posture

The creditor's counsel objected to the chapter 13 trustee's report and filed a motion for the allowance of an administrative expense for professional services rendered, pursuant to 11 U.S.C. § 503(b)(1)(A).

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opinion summary, case decided on February 13, 2007 , LexisNexis #0307-133