In re Hoggarth

Ruling: 
Counsel’s administrative expense claim could not be paid out of undistributed plan paymentson hand at time of conversion. (Bankr. D. Colo.)
Issue: 
Whether Harris prohibited the Trustee from paying counsel's fees (allowed 11 U.S.C.S. § 503(b) administrative expense claim) out of undistributed chapter 13 plan payments held at the time of conversion of this case to a chapter 7 proceeding.
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Consumer case opionion summary, case decided on February 23,2016, LexisNexis #1016-111