By Shane Ramsey ( March 1, 2023, 6:00 PM EST) -- In a November decision, Malloy v. Trak-1 Technology Inc., also known as In re: Kramer, the U.S. Bankruptcy Appellate Panel for the Tenth Circuit held that a Chapter 7 trustee could not sell a limited liability company membership interest pursuant to Section 363 of the Bankruptcy Code because of a transfer restriction within the LLC operating agreement.[1]...
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