Paying Creditors Directly in Chapter 12 Bankruptcy

Abstract

<p>Recent cases in the Sixth and Eighth Circuit Courts of Appeal have allowed debtors under Chapter 12 bankrutpcy to make payments directly to a creditor and avoid paying the trustee's fee. An earlier Ninth Circuit Court of Appeal case had held that a Chapter 12 bankruptcy does not authorize a debtor to make payments directly to creditors for claims modified by the plan in order to avoid paying the trustee's fee.</p>