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In re Brenon K. Farmer and Kristie Elizabeth Farmer

Bankr. No.: 
Date of Decision: 
July 8, 2021
Whether a chapter 7 trustee may include in the trustee's reimbursable expenses the mailing costs for serving another estate professional's fee application and the notice of the application?
Yes. Since the cost to the bankruptcy estate would have been the same whether the estate professional or the chapter 7 trustee made the service, the trustee was allowed to recover the mailing expenses. However, the Court requested chapter 7 trustees and debtors' attorneys in chapter 11, 12, and 13 cases to encourage estate professionals retained in multiple cases to follow Fed.Rs.Bankr.P. 2002(a)(6) and 2016(a) and Bankr. D.S.D. R. 2016-2 and Appendices 2G and 2O and prepare and serve their own fee applications and attendant notices. The United States Trustee should continue to bear the principal burden to review and object to fee applications.
Full Bankruptcy Court Decision: