In re Jartran
United States Court of Appeals for the Seventh Circuit
732 F.2d 584 (1984)
Jartran (debtor), a truck-rental company, contracted with Tinsley and Donnelley (plaintiffs) to place nationwide Yellow Pages ads; each directory had a closing date after which an ad could not be withdrawn, irrevocably fixing Jartran's payment obligation, even though publication and billing occurred months later. When Jartran filed Chapter 11, several ads' closing dates had already passed but publication hadn't occurred yet, and Tinsley and Donnelley continued performing related services like editing and communicating with publishers; they sought administrative-expense priority for the roughly $1.3 million owed for those ads, which the bankruptcy court denied.
Where an expense for services is irrevocably incurred by the debtor prior to the filing of a bankruptcy petition but some performance of the services takes place after the petition is filed and benefits the debtor-in-possession, is the expense entitled to administrative priority?