A party moving under 11 USC 1112(b)(1) for relief such as conversion of a Chapter 11 case to a Chapter 7 case bears the burden of persuasion that cause exists for granting that relief.  Cause includes a material default in making payments due under the Chapter 11 plan.  Material isn’t defined by the Bankruptcy Code, but gains meaning from the concept of material breach of contract.  Here, the bankrupt’s failure to pay over $200,000 for more than six months was a material breach.  Relief could still be denied if the bankruptcy court found “unusual circumstances” made relief inappropriate.  Normal creditor-debtor disputes are not “unusual circumstances” within the meaning of this statute.  The bankruptcy court also properly found that the interests of creditors would be served by conversion since the bankrupt had repeatedly prolonged proceedings and raised meritless arguments to avoid paying creditors.  When a Chapter 11 case is converted to a Chapter 7, the court must decide whether the bankrupt estate vested in the bankrupt upon confirmation of the Chapter 11 plan.  If it didn’t, the property is transferred to the Chapter 7 trustee.  That decision is determined by the express provisions of the Chapter 11 plan, if they address the issue.  If not, it is decided by a holistic examination of the plan to see whether the plan conferred continuing rights in the property to the bankrupt’s creditors, such as continuing security interests and claims that were to be paid from revenue derived from the property.  Here, the bankruptcy court correctly concluded that the property was not transferred, free of creditor’s claims, to the bankrupt on plan confirmation, and hence became property of the Chapter 7 estate on conversion.