In re Philips

ORDER

JAMES R. SACCA, Bankruptcy Judge.

This case presents an issue that has divided bankruptcy courts: how much — if any — of a Chapter 7 Trustee’s fees are allowable when the case is converted before it is fully administered. Courts have issued a variety of rulings on this issue, all of which seem to make some sense, but none of which seems completely correct either — at least not in the underlying reasoning.1 Here, this case was converted from Chapter 7 to Chapter 13 after the Chapter 7 Trustee had performed substantial services related to investigating and liquidating assets but before he…