Debtors were real estate agents. They obtained prospective buyers for several properties before filing a Chapter 7 bankruptcy petition. Their commissions for that work were paid post-petition and were contingent on the post-petition closing of the real estate sale contracts they had negotiated. Held, the commissions are property of the estate. So long as the post-petition payment is for pre-petition services and thus sufficiently rooted in the pre-bankruptcy past, the payment is property of the estate even though it is contingent on post-petition events.
Ninth Circuit Court of Appeals Bankruptcy Appellate Panel (Jury, J.); August 11, 2017; 2017 WL 3466591