In 2005, ' 503(b)(9) was added to the Bankruptcy Code to provide an administrative priority claim for the “value of any goods received by the debtor within 20 days before
'Would You Like Fries with That?'
Recent court decisions addressing the classification of "goods" versus "services" have shed some light on the proper definition of "goods" in the context of whether a particular claim is for "goods" under ' 503(b)(9). However, these decisions have left open some key questions.
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