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Chapter 11, Title 11, United States Code

From Wikipedia, the free encyclopedia

Chapter 11 is a chapter of Title 11, the United States Bankruptcy Code, which permits reorganization under the bankruptcy laws of the United States. Chapter 11 bankruptcy is available to every business, whether organized as a corporation, partnership or sole proprietorship, and to individuals, although it is most prominently used by corporate entities.[1] In contrast, Chapter 7 governs the process of a liquidation bankruptcy (although liquidation can go under this chapter), while Chapter 13 provides a reorganization process for the majority of private individuals.

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  • Chapter 11: Bankruptcy restructuring | Stocks and bonds | Finance & Capital Markets | Khan Academy
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  • "Individuals Filing for Chapter 11 Bankruptcy," With Professor Rich Hynes

Transcription

In the last video we talked about the scenario where a company, for whatever reason, it just couldn't pay it's debt holders. So let's say these are debt holders right here. This is the debt, or the liabilities. It couldn't pay it's debt holders. It went into bankruptcy, and it was determined that these assets that it had right here, that it made no sense operating them as a company. And then the bankruptcy court essentially just decided to liquidate it. And we learned that the debt holders were actually more senior to the equity holders. And they get paid first. And if there wasn't enough money to pay all of the debt holders, then the equity holders got nothing. And that was called a Chapter 7. We're just focusing on the corporate world right now. Maybe we'll do personal soon. So that's Chapter 7 liquidation. That was the last video. And in that case, and I think that's what most people associate when you say that a company has gone bankrupt. That it'll just disappear. That people just say, OK, these assets don't make any sense. They can't pay these guys. We're just going to take these into possession by the courts and then just liquidate the assets. But that raises kind of an obvious question of, well, what if these assets are worth something? What if I sell a socks website, and socks have gotten even more popular. And the only problem is I just can't pay all of the interest that I owe on the debt. Right? Maybe, for whatever reason, I took out a really crazy loan that was variable rate. Or for some reason, I have to pay back some loans because I messed-- and I'll talk more about covenants and things like that. Covenants are pretty much a bunch of rules that the debt holders say, look, you're good, but if any of these x, y, or z things happen, we can take you into bankruptcy. And we could force you into bankruptcy. So maybe because of that, I'm in bankruptcy. But it's determined that these assets, right here, are actually worth more as an operating entity than they are if you were to liquidate them. A good example might be, I don't know, a car company. Right? Let's actually take this example as a car company, because it's very salient to our, at least it was-- I've heard a lot less about the auto bailouts, but it was very salient at the end of last year. So let's say that these are car factories and land and whatever else. And if we're the debt holders, and let's say it goes into bankruptcy. Let's say this is generating cash. And I'll teach you in a future video how do you see what is the cash being generated by the assets. And then you have to subtract out the cash that has to be used to pay the debt holders, because you're paying interest, and then what's left over for equity. And I'll show you how to do that on an income statement. But let's say this is generating a lot of cash. Right? It's generating a good bit of cash, but let's say, these guys eat up interest. Right? So some of the cash will go to the debt holders as interest. And let's say, for whatever reason, either interest rates went up, or they had a bad quarter or a bad year, and they just didn't generate enough cash, let's say they couldn't pay off one of the debt holders. And that debt holder says, hey, you couldn't pay my interest payment, or you couldn't pay the principal payment. I'm taking you into bankruptcy. Right? I'm taking you into bankruptcy. So it goes into bankruptcy. And in this situation, immediately we realize it makes no sense to shutter this asset. If we were just to shut down the factory and lay off the employees, we're going to get nothing for these assets. Because the land is in a part of the country where'd there's no obvious buyer for the land. An empty car factory is pretty much useless, especially when the other people in the industry are in no mood to buy the factories from you. So everyone decides that it's in their best interests to keep this thing running. So what happens is that the debtor stays in possession of the assets. So you can kind of view the debtor as the equity holders and the management of the company. So they stay in possession of the assets. And actually what happens is-- because these guys didn't have enough cash to pay off their debt holders-- what happens is that they take on a new loan, called a debtor-in-possession loan. And this new loan is the most senior loan. It's called DIP financing. It's actually a great business, although it's become scarce recently. It's a great business because you're at the top of the stack. You're more senior than even the senior guys. And it's called DIP financing. Debtor-in-possession financing. And what this provides is a company with some kind of cushion cash so that it can keep operating, so it can keep the lights on. So it's essentially a debt. It's just a very senior type of debt. And it happens once a company has entered bankruptcy. Right? And this bankruptcy that we're going to talk about is Chapter 11. Chapter 11 restructuring. And in Chapter 11 restructuring, you keep operating the company. You might do some things on the left-hand side of the equation. You might want to sell off some of the assets and all of that, but we won't go into that. Most of what you do is you rearrange this side of the balance sheet. And this is why, you probably-- every airline has, some of them, have gone into bankruptcy multiple times, but they still exist. It's not like when you go into bankruptcy the company just disappears. The assets will persist and all of this gets reorganized on this side. A lot of times when someone goes into Chapter 11 and then they come out of it and they go back into it, they call that Chapter 22, and then Chapter 33. I think you get the idea. So anyway, what happens in Chapter 11? So the assets-- essentially it becomes kind of the bankruptcy court takes over, and they hire some investments. They'll get the debtor-in-possession financing so that the company has some cash to operate, pay the bills, and pay the employees and whatever else. The company keeps operating as it always would so it can pay its suppliers and operate as a regular business. And then all of these guys hire a bunch of lawyers. And they start negotiating with each other. And essentially there will be a bank associated with the bankruptcy court whose whole job-- and it's all part of a negotiation-- is to value this. And it's often, maybe this debtor right here, he'll hire one bank. This debtor will hire one bank. Maybe the management will hire another bank. And everyone's going to come up with bankruptcy plans. But bankruptcy plans are usually of one or more varieties. It's essentially just saying, well, we need to value these assets, right? We're not selling it. So we're not just going to get cash. We're going to hire some bankers. And we'll do a lot of videos on that in the future. And they're just going to say-- based on the prospects of this company, how fast it's growing or how fast it's not growing, or how much cash it's generating in a year-- they're going to assign a value to it. So let's say that this guy up here, he hires a banker. And this banker says-- Let's say this was originally the same situation. This was $10 million. Let's say that the liabilities were $6 million. And that the original equity was $4 million. Right? And let's say these bankers evaluate the business. They make detailed models. They take it in the context of the current macro environment. And they say, you know what? I think this company is actually only worth $5 million. And given that it's worth $5 million, and we think that it can sustain-- it's only worth $5 million and there's no way that it can pay interest on $6 million of debt. Right? It doesn't have enough cash to generate $6 million of debt. We think it can afford $2 million of debt. Right? So what will happen is, the new company-- And this is just a plan. And then once you have a plan, then everyone has to vote on it, and there are things called cram downs-- and we''l do that in more detail-- but the plan will say, you know what? The assets are worth $5 million. I thought I was using the square tool. Undo. This plan might say, you know, those assets are worth $5 million. And the company can only handle $2 million of debt, not $6 million of debt. So now, it can only handle $2 million of debt, and then there will be $3 million left of equity. Right? And I'll call this the new equity. Because sometimes this can get confusing. So let's just say for a second-- and I want you to think about it-- what is everyone's incentive? This guy up here, his incentive is to value the company as lowly as possible, right? Because then he gets more of the company. I think that'll be clear to you in a second. This guy's incentive is to say, no, this company is worth a lot. So all of you guys are going to get paid back and then I get what's left over. And you're probably asking, what do you get paid back for not liquidating it? And the answer is the new shares of the company. So what happens is that this stock-- let's say this plan gets passed. This plan right here. In this situation, these guys up here were the most senior, right? Let's say there was $2 million of senior debt up here. Let me write that in a different color. There's $2 million of senior debt up here. So what they'll do is they'll actually get $2 million of the new debt. They're most senior. And then all of these other $4 million, who are more junior-- let me see if I can color it in. I know it's hard to read-- these other $4 million guys, instead of getting any kind of cash or any kind of debt securities for having been owed this money, they'll get the new stock. So they'll get $3 million of new stock. Let me see if I can draw that in. So this $3 million of new equity will go to these guys. And this unsecured guy down here, he's not going to get as much equity. He'll be impaired a little bit. And the old equity guys, the stock's going to go to 0. They're not going to get anything. So the old shareholders of the company are wiped out. They go to 0. And essentially, the debt holders become the new shareholders of the company. You'll often see when a company goes into bankruptcy but it's getting reorganized, you'll often see some people start to buy up this debt or these bonds, right here, because they want to be the new equity holders. When this company emerges from bankruptcy-- let's say that this is how it emerges from bankruptcy-- they want to be these guys, the new equity holders. Because usually when you value it, you want to undervalue it a little bit. I know I've overdrawn this picture a little bit too much. But the debt guys, especially the senior debt guys, they want to be safe. They want to say, you know what? We've already been hurt by this company. They're already not paying our debt. We want to assign as low a possible value to the company as possible-- in this case $5 million-- so that we make sure. Hopefully the company ends up being worth $10 million again, in which case these guys right here make out like bandits, right? If the company was really worth $10 million but the bankruptcy court values it at $5 million, these guys get all of the shares of the company. These guys get wiped out, even though the company really was worth something. So let's say the company emerges from bankruptcy like this, but it actually turns out there were $10 million. Then let's say a year later the company starts doing well again. And let's say that someone could value the company again at $10 million. Now it only has $2 million of debt. And now you have $8 million worth of equity. So these guys-- maybe they were owed $2 or $3 million before, and they got $3 million of the new equity, they might have made out like bandits. Because now all of a sudden, that equity could be worth a lot. That's not always the case. But that's the view from the debt holders' point of view. The equity holders, you can imagine, they don't want to be left with nothing. They'll hire their own bankers. And their bankers, they'll probably submit a plan that says, no, no, no, no. This company is worth at least $8 million. So up here $8 million. And we think it can handle $4 million of debt. So they'd want a scenario like this, where they think the company's worth $8 million. It can handle $4 million worth of debt. And so it has $4 million worth of equity. And of course, the first $6 million of the value-- so the $4 million of debt, and then $2 million of the equity will go to the debt holders, right? Because they were owed $6 million to begin with. And then what's left over, which is essentially-- so this is $2 million of equity, and then you'd have $2 million of equity here-- this $2 million of new equity, right? This is the new shares of the company will be given to the old shareholders of the company. So that's what the shareholders want. I know this gets a little confusing, but it all ends up being valuing the assets as you emerge from bankruptcy. You say, you know, it's generating cash, it's worth something. And then you pay people off according to seniority. And first you pay them off. You say, OK, I still owe you some money. But this company can't support $6 million of debt. It can now support $2 million. And whatever's left, people are paid with actually shares-- new shares-- of the company. Not the old shares. So the old shares will go to 0. So you can imagine a world where GM goes bankrupt. Right now, the shares of GM go to 0. GM old goes to 0. But the assets keep operating, and that's why some people are a little bit misleading in this whole automotive bankruptcy debate. They're kind of using scare tactics to say, oh, if GM goes bankrupt, then these assets are just going to disappear. No, they'll just keep operating. If it makes sense to operate them, they'll keep operating. The only people who will lose big are the old equity holders. And then some of the unsecured, the more junior levels of debt, will probably lose some money. But if the assets are worth operating, they'll continue to operate. And if the people, if it makes sense to have them employed, they'll keep working. See you in the next video.

Contents

Chapter 11 in general

When a business is unable to service its debt or pay its creditors, the business or its creditors can file with a federal bankruptcy court for protection under either Chapter 7 or Chapter 11.

In Chapter 7, the business ceases operations, a trustee sells all of its assets, and then distributes the proceeds to its creditors. Any residual amount is returned to the owners of the company.

In Chapter 11, in most instances the debtor remains in control of its business operations as a debtor in possession, and is subject to the oversight and jurisdiction of the court.[2]

Features of Chapter 11 reorganization

Chapter 11 retains many of the features present in all, or most, bankruptcy proceedings in the U.S. It provides additional tools for debtors as well. Most importantly, 11 U.S.C. § 1108 empowers the trustee to operate the debtor's business. In Chapter 11, unless a separate trustee is appointed for cause, the debtor, as debtor in possession, acts as trustee of the business.[3]

Chapter 11 affords the debtor in possession a number of mechanisms to restructure its business. A debtor in possession can acquire financing and loans on favorable terms by giving new lenders first priority on the business's earnings. The court may also permit the debtor in possession to reject and cancel contracts. Debtors are also protected from other litigation against the business through the imposition of an automatic stay. While the automatic stay is in place, creditors are stayed from any collection attempts or activities against the debtor in possession, and most litigation against the debtor is stayed,[4] or put on hold, until it can be resolved in bankruptcy court, or resumed in its original venue. An example of proceedings that are not necessarily stayed automatically are family law proceedings against a spouse or parent. Further, creditors may file with the court seeking relief from the automatic stay.

If the business is insolvent, its debts exceed its assets and the business is unable to pay debts as they come due,[5] the bankruptcy restructuring may result in the company's owners being left with nothing; instead, the owners' rights and interests are ended and the company's creditors are left with ownership of the newly reorganized company.

All creditors are entitled to be heard by the court.[6] The court is ultimately responsible for determining whether the proposed plan of reorganization complies with the bankruptcy law.

One controversy that has broken out in bankruptcy courts concerns the proper amount of disclosure that the court and other parties are entitled to receive from the members of the ad hoc creditor's committees that play a large role in many such proceedings.[7]

Chapter 11 plan

Chapter 11 usually results in reorganization of the debtor's business or personal assets and debts, but can also be used as a mechanism for liquidation. Debtors may "emerge" from a chapter 11 bankruptcy within a few months or within several years, depending on the size and complexity of the bankruptcy. The Bankruptcy Code accomplishes this objective through the use of a bankruptcy plan. The debtor in possession typically has the first opportunity to propose a plan during the period of exclusivity. This period allows the debtor 120 days from the date of filing for chapter 11, to propose a plan of reorganization before any other party in interest may propose a plan. If the debtor proposes a plan within the 120-day exclusivity period, a 180-day exclusivity period from the date of filing for chapter 11 is granted in order to allow the debtor to gain confirmation of the proposed plan.[4] With some exceptions, the plan may be proposed by any party in interest.[8] Interested creditors then vote for a plan.

Confirmation

If the judge approves the reorganization plan and if the creditors all agree the plan can be confirmed. If at least one class of creditors votes against the plan and thus objects, the plan may nonetheless be confirmed if the requirements of cramdown are met. In order to be confirmed over their objection the plan must not discriminate against that class of creditors, and the plan must be found fair and equitable to that class.

Upon its confirmation, the plan becomes binding and identifies the treatment of debts and operations of the business for the duration of the plan.

If a plan cannot be confirmed, the court may either convert the case to a liquidation under chapter 7, or, if in the best interests of the creditors and the estate, the case may be dismissed resulting in a return to the status quo before bankruptcy. If the case is dismissed, creditors will look to non-bankruptcy law in order to satisfy their claims.

Automatic stay

Like other forms of bankruptcy, petitions filed under chapter 11 invoke the automatic stay of § 362. The automatic stay requires all creditors to cease collection attempts, and makes many post-petition debt collection efforts void or voidable. Under some circumstances, some creditors, otherwise the United States Trustee can request for the court converting the case into a liquidation under chapter 7, or appointing a trustee to manage the debtor's business. The court will grant a motion to convert to chapter 7 or appoint a trustee if either of these actions is in the best interest of all creditors. Sometimes a company will liquidate under chapter 11, in which the pre-existing management may be able to help get a higher price for divisions or other assets than a chapter 7 liquidation would be likely to achieve. Appointment of a trustee requires some wrongdoing or gross mismanagement on the part of existing management and is relatively rare.

Executory contracts

Some contracts, known as executory contracts, may be rejected if canceling them would be financially favorable to the company and its creditors. Such contracts may include labor union contracts, supply or operating contracts (with both vendors and customers), and real estate leases. The standard feature of executory contracts is that each party to the contract has duties remaining under the contract. In the event of a rejection, the remaining parties to the contract become unsecured creditors of the debtor. For example, in some districts a contract for deed is an executory contract, while in others it is not.

In the new millennium airlines have fallen under intense scrutiny for what many see as abusing Chapter 11 Bankruptcy as a simple tool for escaping labor contracts, usually 30-35% of an airline's operating cost.[9] Every major US airline has filed for Chapter 11 since 2002.[10] In the space of 2 years (2002 - 2004) US. Airways filed for bankruptcy twice[11] leaving the AFL-CIO,[12] pilot unions and other airline employees claiming the rules of Chapter 11 have helped turn the USA into a corporatocracy.[13]

Priority

Chapter 11 follows the same priority scheme as other bankruptcy chapters. The priority structure is defined primarily by § 507 of the Bankruptcy Code (11 U.S.C. § 507.)

As a general rule, administrative expenses (the actual, necessary expenses of preserving the bankruptcy estate, including expenses such as employee wages, and the cost of litigating the chapter 11 case)are paid first.[14] Secured creditors—creditors who have a security interest, or collateral, in the debtor's property—will be paid before unsecured creditors. Unsecured creditors' claims are prioritized by § 507. For instance the claims of suppliers of products or employees of a company may be paid before other unsecured creditors are paid. Each priority level must be paid in full before the next lowest priority level may receive payment.

Section 1110

Section 1110 (11 U.S.C. § 1110) generally provides a secured party with an interest in an aircraft the ability to take possession of the equipment within 60 days after a bankruptcy filing unless the airline cures all defaults. More specifically, the right of the lender to take possession of the secured equipment is not hampered by the automatic stay provisions of the U.S. Bankruptcy Code.

Stock

If the company's stock is publicly traded, a Chapter 11 filing generally causes it to be delisted from its primary stock exchange if listed on the New York Stock Exchange, the American Stock Exchange, or the NASDAQ. On the NASDAQ the identifying fifth letter "Q" at the end of a stock symbol indicates the company is in bankruptcy (formerly the "Q" was placed in front of the pre-existing stock symbol; a celebrated example was Penn Central, whose symbol was originally "PC" and became "QPC" after the company filed Chapter 11 in 1970). Many stocks that are delisted quickly resume listing as over-the-counter (OTC) stocks. Actual share value does not reach zero unless the probability of restructuring is so low that a Chapter 7 filing is sure to follow.

Individuals may file Chapter 11, but due to the complexity and expense of the proceeding, this option is rarely chosen by debtors who are eligible for Chapter 7 or Chapter 13 relief.

Rationale

In enacting Chapter 11 of the Bankruptcy code, Congress concluded that it is sometimes the case that the value of a business is greater if sold or reorganized as a going concern than the value of the sum of its parts if the business's assets were to be sold off individually. It follows that it may be more economically efficient to allow a troubled company to continue running, cancel some of its debts, and give ownership of the newly reorganized company to the creditors whose debts were canceled. Alternatively, the business can be sold as a going concern with the net proceeds of the sale distributed to creditors ratably in accordance with statutory priorities. In this way, jobs may be saved, the (previously mismanaged) engine of profitability which is the business is maintained (presumably under better management) rather than being dismantled, and, as a proponent of a chapter 11 plan is required to demonstrate as a precursor to plan confirmation, the business's creditors end up with more money than they would in a Chapter 7 liquidation.

Considerations

The reorganization and court process may take an inordinate amount of time, limiting the chances of a successful outcome and sufficient debtor in possession financing may be unavailable during an economic recession. A preplanned, preagreed approach between the debtor and its creditors (sometimes called a pre-packaged bankruptcy) may facilitate the desired result. A company undergoing Chapter 11 reorganization is effectively operating under the "protection" of the court until it emerges. An example is the airline industry in the United States; in 2006 over half the industry's seating capacity was on airlines that were in Chapter 11.[15] These airlines were able to stop making debt payments, break their previously agreed upon labor union contracts, freeing up cash to expand routes or weather a price war against competitors — all with the bankruptcy court's approval.

Studies on the impact of forestalling the creditors' rights to enforce their security reach different conclusions.[16]

Deadlines

Within 60 days of filing for Chapter 11 bankruptcy, the debtor must submit a written disclosure statement with the court containing information on assets, liabilities and business affairs.[17]

Statistics

Frequency

Chapter 11 cases dropped by 60% from 1991 to 2003. One 2007 study[18] found this was because businesses were turning to bankruptcy-like proceedings under state law, rather than the federal bankruptcy proceedings, including those under chapter 11. Insolvency proceedings under state law, the study stated, are currently faster, less expensive, and more private, with some states not even requiring court filings. However, a 2005 study[18] claimed the drop may have been due to an increase in the incorrect classification of many bankruptcies as "consumer cases" rather than "business cases".

Cases involving more than US$50 million in assets are almost always handled in federal bankruptcy court, and not in bankruptcy-like state proceeding.

Largest cases

The largest bankruptcy in history was of the US investment bank Lehman Brothers Holdings Inc., which listed $639 billion in assets as of its Chapter 11 filing in 2008. The 16 largest corporate bankruptcies as of 13 December 2011:[19]

Company Filing date Total Assets pre-filing Assets adjusted to the year 2012 Filing court district
Lehman Brothers Holdings Inc. 2008-09-15 $639,063,000,800 $726 billion NY-S
Washington Mutual 2008-09-26 $327,913,000,000 $373 billion DE
Worldcom Inc. 2002-07-21 $103,914,000,000 $141 billion NY-S
General Motors Corporation[20] 2009-06-01 $82,300,000,000 $93.9 billion NY-S
CIT Group 2009-11-01 $71,019,200,000 $81 billion NY-S
Enron Corp.* 2001-12-02 $63,392,000,000 $87.6 billion NY-S
Conseco, Inc. 2002-12-18 $61,392,000,000 $83.5 billion IL-N
MF Global 2011-10-31 $41,000,000,000 $44.6 billion NY-S
Chrysler LLC[21] 2009-04-30 $39,300,000,000 $44.8 billion NY-S
Texaco, Inc. 1987-04-12 $35,892,000,000 $77.3 billion NY-S
Financial Corp. of America 1988-09-09 $33,864,000,000 $70.1 billion CA-C
Penn Central Transportation Company[22] 1970-06-21 $7,000,000,000 $44.1 billion PA-S
Refco Inc. 2005-10-17 $33,333,172,000 $41.8 billion NY-S
Global Crossing Ltd. 2002-01-28 $30,185,000,000 $41.1 billion NY-S
Pacific Gas and Electric Co. 2001-04-06 $29,770,000,000 $41.1 billion CA-N
UAL Corp. 2002-12-09 $25,197,000,000 $34.3 billion IL-N
Delta Air Lines, Inc. 2005-09-14 $21,801,000,000 $27.3 billion NY-S
Delphi Corporation, Inc. 2005-10-08 $22,000,000,000 $27.3 billion NY-S

Enron, Lehman Brothers, MF Global and Refco have all ceased operations while others were acquired by other buyers or emerged as a new company with a similar name.

The Enron assets were taken from the 10-Q filed on November 11, 2001. The company announced that the annual financials were under review at the time of filing for Chapter 11.

See also

Similar programs in other countries

References

  1. ^ "Chapter 11 - Bankruptcy Basics". United States Courts. Retrieved 5 August 2015. 
  2. ^ Joseph Swanson and Peter Marshall, Houlihan Lokey and Lyndon Norley, Kirkland & Ellis International LLP (2008). A Practitioner's Guide to Corporate Restructuring. City & Financial Publishing, 1st edition ISBN 978-1-905121-31-1
  3. ^ 11 U.S.C. § 1107
  4. ^ a b "11 U.S. Code § 362 - Automatic stay". Retrieved 5 August 2015. 
  5. ^ "§ 1-201. General Definitions". Retrieved 5 August 2015. 
  6. ^ 1 U.S.C. Sec. 1109 (b)
  7. ^ "Bankruptcy Rules Committee rethinks 2019 pricing disclosure amid HF panic attack". Financial Times. Retrieved 5 August 2015. 
  8. ^ 11 U.S.C. § 1121
  9. ^ "massachusetts institute of technology: Airline Data Project". MIT. 
  10. ^ Davies, Richard (Nov 29, 2011). "AMR Files for Bankruptcy: The Last Giant to Fall". ABC News. Retrieved 19 May 2012. 
  11. ^ Warner, Margeret (Sep 13, 2004). "US Airways Files....Again". Public Broadcasting Service. Retrieved 19 May 2012. 
  12. ^ Jablonski, Donna. "AFL-CIO Cries Foul". AFL-CIO. Retrieved 19 May 2012. 
  13. ^ Trumbul, Mark (Nov 29, 2011). "AMR Files for Chapter 11". The Christian Science Monitor. Retrieved 19 May 2012. 
  14. ^ "11 U.S. Code § 503 - Allowance of administrative expenses". Retrieved 5 August 2015. 
  15. ^ Isidore, Chris; Senior, /Money (2005-09-14). "Delta and Northwest airlines both file for bankruptcy". CNN. Retrieved November 17, 2005. 
  16. ^ "The night of the killer zombies". Economist.com. 2002-12-12. Retrieved 2006-08-05. 
  17. ^ "3 Deadlines to Beware of When Filing a Chapter 11 Bankruptcy". DCDM. 2014-02-17. Retrieved 2014-10-15. 
  18. ^ a b (January 24, 2007), "Small Firms Spurn Chapter 11", Wall Street Journal, page B6B
  19. ^ Bankruptcydata.com
  20. ^ "Bankruptcy Reorganization Chapter". Retrieved 5 August 2015. 
  21. ^ "Bankruptcy Reorganization Chapter". Retrieved 5 August 2015. 
  22. ^ Dascher, Paul E. (1 January 1972). "The Penn Central Revisited: A Predictable Situation". Financial Analysts Journal. 28 (2): 61–64. JSTOR 4470905. 

External links

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