LOKEN, Circuit Judge.
In September 2005, GELCO Corporation ("GELCO") entered into a sales-commission agreement ("SCA") with Dennis Hecker and two of Hecker's companies whereby GELCO acquired vehicle fleet-leasing assets in exchange for $20 million plus a series of deferred, formula-based incentive payments. Hecker petitioned for protection under Chapter 7 of the Bankruptcy Code in June 2009, listing the SCA as non-exempt personal property with an estimated value of...
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