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party owed the commissions had failed to object to the sale, and the commission obligation was not mentioned in the purchase agreement or order approving the sale.
Two cases vacate sales for inadequate price. In re Berg, 383 B.R. 631 (Bk. W.D. Tex. 2008) (seriously mistaken view on amount of royalty revenue); In re Hart's Mfg. Co., 383 B.R. 720 (Bk. W.D. Tenn. 2008) (gross inadequacy of price).
In re Shenango Group Inc., 501 F.3d 338 (3d Cir. 2007) (court had related to jurisdiction over claim by retirees that plan required debtor immediately to fund pension plan because there was a close nexus between the question and the plan; matters affecting interpretation, implementation, consummation, execution or administration of the plan typically have such a close nexus; court on review of plan interpretation issues gives substantial deference to opinion of bankruptcy judge who confirmed the plan).
A recent decision may be read to suggest that there may be a somewhat different standard for transferring venue in a real estate case. See In re Dunmore Homes, Inc., 380 B.R. 663 (Bk. S.D.N.Y. 2008) (transfer to primary location of properties of developer).
©2008 Jonathan M. Landers
