Costs incurred by the debtors' landlord in efforts at the appellate level to collect post-petition rent were not recoverable as administrative expenses under § 365(d)(3) because that section applies only until assumption or rejection of a lease.

The court reopened the case and abstained from determining the debtor's liability for payroll taxes. The lawsuit's outcome would have no effect on the bankruptcy estate, and the bankruptcy court had no authority over a non-debtor responsible party.

*Reversed at 613 F.3d 810.* A farm lessor whose rent payment came due post-petition is entitled to an administrative expense claim under § 365(d)(3) for the prorated amount of rent attributable to post-petition, pre-rejection use of the property.

Summary judgment was denied on the non-dischargeability of a debt under § 523(a)(2)(A) because there was a factual dispute as to whether the debtor led a materials supplier to believe he had secured bank financing with which to pay off his open account.

The parties' vehicle lease was actually an installment sale/security agreement rather than a true lease. Accordingly, the debtors were entitled to the balance of the proceeds of an insurance check issued when the vehicle was totaled in an accident.

A Chap. 13 projected disposable income calculation should use the amount of actual plan payments to secured creditors, rather than the amount contractually due, as the plan likely alters the amount due & the statute refers to plan's effective date.

The $50 late charge for each day debtors' rent was past due should not have been cumulative; rather, it should have simply been charged per day for each day that any rent remained unpaid between the date of abandonment and the date of bankruptcy filing.

Plan confirmation was denied because the debtor needed to amend to provide for adequate protection payments to begin at confirmation and to clarify that he was surrendering his interest in certain collateral. The Till interest rate was appropriate.

Because the debtors had no equity in property they proposed to sell, and it wasn't necessary for an effective reorganization, and its sale would not benefit the estate, the court denied the motion to sell and granted lienholders relief to foreclose.

On summary judgment, the court determined priority of creditors' interests; (1) creditor bank, though first to file, had not properly perfected its lien under the U.C.C. and (2) creditor landlord's lien is superior to each creditor bank's interest.