San Diego Law Review


Katherine Kruis

Library of Congress Authority File


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For almost a century, bankruptcy trustees have argued with courts regarding appropriate compensation. In 1899, a trustee petitioned the court for a lump sum in lieu of the 3 percent commission allowed under the 1898 Bankruptcy Act. The court held that "the 3 percent commission was amply compensation for all the services performed, and it was the only type of compensation allowed under the [A]ct." In 1986, a trustee submitted a fee application to the court based upon the maximum statutory amount allowed under the 1978 Bankruptcy code. The bankruptcy court reduced the fee. On appeal, the district court affirmed the award concluding there was no abuse of discretion in the fee reduction.

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