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Abstract

In the very recent case of Manhattan Properties, Inc. v. Irving Trust Co., the Supreme Court for the first time authoritatively passed on the validity of a claim in bankruptcy by a lessor against the bankrupt estate for loss of future rents due after the filing of the petition. The Court, affirming the decision of the Circuit Court of Appeals, ruled that the landlord's claim was not provable. Mr. Justice Roberts, delivering the opinion of the Court, reviewed the long history of litigation on the subject and was impressed by the fact that although the great majority of the lower federal. courts had consistently excluded claims for future rents from the class of provable debts, Congress in the interim had done nothing.

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