Ninth Circuit Creates a Legal Fiction to Uphold Recovery of an Unauthorized Transfer
Ninth Circuit assumed that transferred property must remain property of the estate after conversion from ‘13’ to ‘7’ before the chapter 7 trustee can avoid an unauthorized transfer under Section 549.
Ninth Circuit BAP Applies Taggart to Violations of the Automatic Stay
Taggart left open the question of whether the ‘no objectively reasonable basis’ standard for discharge violations also applies to contempt of the automatic stay.