Fitness Holdings Could Give Recharacterization Quite a Workout
Journal of Corporate Renewal
The United States Court of Appeals for the Ninth Circuit issued its opinion in In re Fitness Holdings Int’l, 714 F.3d 1141 (9th Cir. 2013), on April 30 of this year, reversing more than 25 years of practice in the Ninth Circuit under the rule of In re Pacific Express, Inc., 69 B.R. 112 (B.A.P. 9th Cir. 1986).