Recent cases in the Sixth and Eighth Circuit Courts of Appeal have allowed debtors under Chapter 12 bankrutpcy to make payments directly to a creditor and avoid paying the trustee's fee. An earlier Ninth Circuit Court of Appeal case had held that a Chapter 12 bankruptcy does not authorize a debtor to make payments directly to creditors for claims modified by the plan in order to avoid paying the trustee's fee.
"Paying Creditors Directly in Chapter 12 Bankruptcy,"
Agricultural Law Digest: Vol. 6
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol6/iss10/1