In Hallmark v. Athens/Alpha Gas Corp., 2005 Bankr. LEXIS 2097 (8th Cir. 2005), the Court was presented with an issue of whether a creditor's post-petition right to receive a share of revenue distribution is sufficient to grant it an administrative claim. Administrative priority claims are preferred over unsecured claims since they are paid with what bankruptcy lawyers call "hundred cent dollars" whereas the unsecured claims may only receive "pennies on the dollar" ? if anything. In this matter, the debtor and creditors jointly owned an oil and gas well. The debtor operated the well and owned approximately 50 percent of the working interest. The creditors (the "appellants"), who are a party to this matter, own approximately 45 percent. Income and expenses were to be divided based on these percentages. In October 2002, the debtor filed its Chapter 11 petition. The well turned a profit of approximately $1 million but the proceeds were used to pay operating expenses and debts unrelated to the well instead of distributing the funds. The appellants sought an administrative claim for their share of post-petition gross revenues. The bankruptcy court ruled in favor of the debtor and denied the claim stating that there was no post-petition transaction from which the debt arose, the appellants incurred no actual expense, and they did not benefit the estate. The 8th Circuit Court of Appeals disagreed. The Court held that the agreement regarding revenue distribution was a pre-petition agreement, but the appellants' right to its share arose post-petition. Further, it stated that "the transaction was the debtor's post-petition act of exercising control of all the profits, thereby depriving the appellants of their revenue." Further, "[b]y the debtor's actions, the appellants were unwittingly forced to make a post-petition investment in the business to keep it operating." The Court also said that by keeping the profits and using at least a portion to operate the business, the estate was benefitted. The Court reversed the Bankruptcy Court's decision and awarded the appellants an administrative claim. Ray