Daniel M. Press, VSB# 37123 

Chung & Press, P.C. 

6718 Whittier Ave., Suite 200 

McLean, VA 22101 

(703) 734-3800 

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

(Alexandria Division) 

---------------------------------------------------------------X 

In re: : Chapter 11 

 : 

Martin Alan Burke : No. 18−13979−BFK 

Debtor. : 

 : 

---------------------------------------------------------------X 

FINAL REPORT AND MOTION FOR FINAL DECREE AND TO CLOSE CASE 

 COMES NOW Martin Alan Burke (the “Debtor”), the reorganized debtor herein, 

by his undersigned counsel, and submits this Final Report and Motion for Final Decree 

and to Close Case (the “Motion for Final Decree”). Contemporaneously herewith, the 

Debtor is also submitting a Final Account that should be considered in evaluating the 

Debtor’s Motion for Final Decree. 

 1. On November 27, 2018 (the “Petition Date”), the Debtor commenced this 

voluntary chapter 11 bankruptcy case. 

 2. The Debtor is an individual resident of Loudoun County, Virginia (Fairfax 

County as of the Petition Date). He is employed as the president of Integrated Solutions 

Management, Inc., a privately-held technology company in which he is also a shareholder. 

The Debtor resides in a home that he rents, having sold his prior home during the case to 

reduce expenses. 

 3. By Order entered February 26, 2020, (the “Confirmation Order”), the 

Court confirmed the Debtor’s Plan of Reorganization (the “Plan”). 

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 4. Subsequently, the Debtor has undertaken those steps necessary to 

substantially consummate the confirmed Plan as provided under Section 1101(2) of Title 

11 of the United States Code (the “Bankruptcy Code”). More specifically, the Debtor has 

commenced distribution under the Plan. Each of the requirements under Section 1101(2) 

of the Bankruptcy Code is summarized below. There has been substantial consummation 

of the Plan confirmed by the Court on February 26, 2020. No property was required by 

the Plan to be transferred; the debtor has assumed the management of all the property 

dealt with by the plan; and the debtor has commenced distribution under the plan. Each of 

these three requirements under 11 USC §1101(2) is summarized below. 

I. Transfer of Property. 

 The Plan proposes no transfers of property. Accordingly, all property transfers 

anticipated by the Plan have been completed. 

II. Assumption by Debtors of Management of Property. 

 The plan provided for the debtor to stay in control of his assets after confirmation. 

Since the date of confirmation, the debtor has remained in control and has operated 

pursuant to the terms of the plan. 

III. Distributions. 

 After the effective date, March 12, 2020, the Debtor commenced distributions 

under the plan. The Debtor has paid all administrative expenses that have come due 

(except for the final fee application of counsel for the Debtor, which is being heard 

concurrently with this Motion), has made all payments required on secured loans for 

property being retained (class C), and has commenced making payments on the Priority 

Tax claim in accordance with Plan provisions and in the Final Report attached hereto as 

Exhibit A. The Plan provides for payment of secured tax claims (Class B) after 

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completion of payments to Priority taxes. The Debtor asks for approval of his Final 

Report. 

MOTION FOR FINAL DECREE 

 As indicated above, the Debtor has substantially consummated the Plan as 

provided under Section 1101(2) of the Bankruptcy Code. To the best of the Debtor’s 

knowledge, all allowed administrative claims have been paid, and the final administrative 

expenses, compensation of counsel for the Debtor and payment of the final U.S. Trustee 

fee for the present quarter, will be paid in conjunction with the approval of this motion. 

Debtor does not anticipate that there will be any further administrative claims sought by 

creditors. The Debtor has completed the transfer of all property to be transferred under 

the Plan. All pending motions, contested matters and adversary proceedings have been 

resolved or will be resolved prior to or concurrently with a hearing on this Motion. The 

Debtor will pay any outstanding quarterly fees to the Office of the United States Trustee 

through the third quarter of 2020 in conjunction with the Court’s approval of this motion. 

 WHEREFORE, Debtor respectfully seeks entry of an Order by this Court: (i) 

approving the Debtor’s final report; (ii) granting the Debtor’s Motion for entry of a Final 

Decree in this case, and closing the case, subject to reopening for entry of a discharge; 

and (iii) for such further relief as the Court deems just and appropriate. 

 Dated: September 3, 2020. 

 Respectfully submitted, 

 _/s/ Daniel M. Press_____________ 

 Daniel M. Press, VSB 37123 

 Chung & Press, P.C. 

 6718 Whittier Ave., Suite 200 

 McLean, VA 22101 

 (703) 734-3800/(703) 734-0590 fax 

 dpress@chung-press.com 

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CERIFICATE OF SERVICE 

 This is to certify that on this 3rd day of September, 2020, I caused the foregoing 

document to be served on the US Trustee and all persons requesting notice by CM/ECF. 

 _/s/ Daniel M. Press_____________ 

 Daniel M. Press 

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