In the Matter of Joseph ANDREUCCETTI & Noemi Andreuccetti, Debtors-Appellants, 975 F.2d 413 (7th Cir. 1992). · Go Syfert
In the Matter of Joseph ANDREUCCETTI & Noemi Andreuccetti, Debtors-Appellants, 975 F.2d 413 (7th Cir. 1992). Cases Citing This Book View Copy Cite
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200 citation events (115 in the last 25 years) across 31 distinct courts.
Strongest positive: Mercy Health Network v. Mercy Hospital, Iowa City, IA (ca8, 2026-06-12) · Strongest negative: In Re Envirodyne Industries, Inc. (ilnb, 1994-09-26)
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discussed Cited "but see" In Re Envirodyne Industries, Inc.
Bankr. N.D. Ill. · 1994 · signal: but see · confidence high
See Enmrodyne, 29 F.3d at 303; but see In re Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992) (stating that mootness involves an individualized assessment to determine if judicial relief is available as a practical matter).
discussed Cited as authority (rule) Mercy Health Network v. Mercy Hospital, Iowa City, IA
8th Cir. · 2026 · confidence medium
See, e.g., In re Krause, 637 F.3d at 1168 (remarking that “[t]hird-party standing is of special concern in the bankruptcy -8- context” and refusing to consider a bankruptcy challenge when “[t]hose affected by the bankruptcy court’s order . . . d[id] not seek to appeal [it]” (quoting Kane v. Johns-Manville Corp., 843 F.2d 636, 644 (2d Cir. 1988)); In re Andreuccetti, 975 F.2d 413, 420 (7th Cir. 1992) (concluding that the appellants “lack[ed] standing to challenge” certain claims because they did not “hold any of [them], nor d[id] they assert” that they were “adversely affect…
cited Cited as authority (rule) In re: Eunice Murray
Bankr. S.D. Florida · 2026 · confidence medium
Ill. 2019) (citing In re Andreuccetti, 975 F.2d 413, 417 (7th Cir. 1992) (debtors had standing to appeal only because of the possibility of a surplus); In re Rybka, 339 B.R. 464, 467 (Bankr.
discussed Cited as authority (rule) Helmstetter v. Herzog
N.D. Ill. · 2021 · confidence medium
It further explained that “[i]f the debtor can show a reasonable possibility of a surplus after satisfying all debts, then the debtor has shown a pecuniary interest and has standing to object to a bankruptcy order.” Id. at 608; see also, e.g., Stinnett, 465 F.3d at 315 (quoting same); In re Andreuccetti, 975 F.2d 413, 416 (7th Cir. 1992) (“A ‘person aggrieved’ by a bankruptcy order must demonstrate that the order diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.” (internal quotation marks omitted)).
discussed Cited as authority (rule) Laz (2×)
N.D. Ill. · 2019 · confidence medium
Standing in this context is “narrower than Article III standing.” In re Cult Awareness Network, Inc., 151 F.3d 605 , 607 (7th Cir. 1998) (citing Matter of Andreucetti, 975 F.2d 413, 416 (7th Cir. 1992)).
cited Cited as authority (rule) Knott v. Woodstock Farm & Fleet, Inc.
Ill. App. Ct. · 2017 · confidence medium
In re Andreuccetti, 975 F.2d 413, 417 (7th Cir. 1992).
cited Cited as authority (rule) Knott v. Woodstock Farm & Fleet, Inc.
Ill. App. Ct. · 2017 · confidence medium
In re Andreuccetti, 975 F.2d 413, 417 (7th Cir. 1992).
discussed Cited as authority (rule) In re Presswood (2×) also: Cited "see, e.g."
Bankr. S.D. Ill. · 2016 · confidence medium
In re Cult Awareness Network, Inc., 151 F.3d 605 , 607 (7th Cir, 1998). 5 See also Matter of Andreuccetti, 975 F.2d 413, 416 (7th Cir. 1992).
cited Cited as authority (rule) Buridi v. KMC Real Estate Investors, LLC
S.D. Ind. · 2014 · confidence medium
In re Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992).
discussed Cited as authority (rule) Hijjawi v. Five North Wabash Condominium Ass'n
Bankr. N.D. Ill. · 2013 · confidence medium
In assessing mootness, “the reviewing court must scrutinize each individual claim” and “reach a determination upon close consideration of the relief sought in light of the facts of the particular case.” In re Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992) (internal citations and quotation marks omitted); see also Envi-rodyne, 29 F.3d at 303-04 (“A case is moot if there is no possible relief which the court could order that would benefit the party seeking it.
discussed Cited as authority (rule) In re Witt
Bankr. N.D. Ind. · 2012 · confidence medium
Holloway Foundation, 36 F.3d 582, 585-86 (7th Cir.1994); Matter of Andreuccetti, 975 F.2d 413, 420-21 (7th Cir.1992); Matter of Energy Co-op., Inc., 886 F.2d 921, 929 (7th Cir.1989); In re American Reserve Corp., 841 F.2d 159 , 162 (7th Cir.1987), in their brief on the issue counsel never mentioned or attempted to apply it to the case at hand.
discussed Cited as authority (rule) United States v. Krause
10th Cir. · 2011 · confidence medium
See, e.g., Holmes v. Silver Wings Aviation, Inc., 881 F.2d 939, 940 (10th Cir.1989); In re El San Juan Hotel, 809 F.2d 151, 154 (1st Cir.1987); In re PWS Holding Corp., 228 F.3d 224 , 228 (3d Cir.2000); In re LTV Steel Co., Inc., 560 F.3d 449, 452 (6th Cir.2009); Matter of Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992); Matter of Fondiller, 707 F.2d 441, 442-43 (9th Cir. 1983).
discussed Cited as authority (rule) In Re Greenwood Point, LP
Bankr. S.D. Ind. · 2011 · confidence medium
“Good faith” is not defined in the Bankruptcy Code, but generally means that there is a reasonable likelihood that the proposed plan will achieve results that are consistent with the objectives of the Bankruptcy Code. 203 North LaSalle, 126 F.3d at 969 ; In re Madison Hotel Associates, 749 F.2d 410, 425 (7th Cir.1984); In re Andreuccetti, 975 F.2d 413, 420 (7th Cir.1992).
discussed Cited as authority (rule) Boyer v. Trustees of Indiana University (In re Fort Wayne Telsat, Inc.) (2×) also: Cited "see"
Bankr. N.D. Ind. · 2010 · confidence medium
Matter of Andreuccetti, 975 F.2d 413, 421 (7th Cir.1992); In re American Reserve Corp., 841 F.2d 159 , 162 (7th Cir.1987).
discussed Cited as authority (rule) In Re Adams
Bankr. N.D. Ill. · 2010 · confidence medium
To have standing to object to a bankruptcy court’s order, a person must have “a pecuniary interest in the outcome of the bankruptcy proceedings.” Cult Awareness Network, 151 F.3d at 607; see also Ray, 597 F.3d at 874-75 , 2010 WL 759838 , at *3; In re Stinnett, 465 F.3d 309 , 315 (7th Cir.2006); In re Andreuccetti 975 F.2d 413, 416 (7th Cir.1992); In re Ulz, 401 B.R. 321, 327 (Bankr.
discussed Cited as authority (rule) In Re Ray
7th Cir. · 2010 · confidence medium
In addition to the appearance and objection prerequisites, “[o]nly those persons affected pecuniarily by a bankruptcy order have standing to appeal that order.” In re Stinnett, 465 F.3d 309 , 315 (7th Cir.2006) (citing In re Cult Awareness Network, Inc., 151 F.3d at 607-08). “[A] person has standing to object to an order if that person can ‘demonstrate that the order diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.’ ” In re Cult Awareness Network, 151 F.3d at 608 (citing In re DuPage Boiler Works, Inc., 965 F.2d 296, 297 (7th C…
discussed Cited as authority (rule) Becker & Poliakoff PA v. Ward Feed Yard, Incorporated
7th Cir. · 2010 · confidence medium
In addition to the appearance and objection prerequisites, “[o]nly those persons affected pecuniarily by a bankruptcy order have standing to appeal that order.” In re Stinnett, 465 F.3d 309 , 315 (7th Cir. 2006) (citing In re Cult Awareness Network, Inc., 151 F.3d at 607- 08). “[A] person has standing to object to an order if that person can ‘demonstrate that the order diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.’ ” In re Cult Awareness Network, 151 F.3d at 608 (citing In re DuPage Boiler Workers, Inc., 965 F.2d 296, 297 (7…
cited Cited as authority (rule) In Re Sentinel Management Group, Inc.
Bankr. N.D. Ill. · 2009 · confidence medium
In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992) (internal quotation omitted).
discussed Cited as authority (rule) In Re Stoller
Bankr. N.D. Ill. · 2007 · confidence medium
In other words, Mr. Stoller has failed to “show a reasonable possibility of a surplus after satisfying all debts,” Cult Awareness Network, 151 F.3d at 608 (citing In re Andreuccetti, 975 F.2d 413, 417 (7th Cir.1992)), that would bring him within the exception to the “pecuniary interest” rule.
cited Cited as authority (rule) In Re Carl F. Semrau DDS, Ltd.
Bankr. N.D. Ill. · 2006 · confidence medium
In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992) (internal quotation omitted).
discussed Cited as authority (rule) United Retired Pilot v. UAL Inc
7th Cir. · 2006 · confidence medium
In re UNR Industries, Inc. 20 F.3d 766 (7th Cir. 1994); In re Andreuccetti, 975 F.2d 413, 415, 417-19 (7th Cir. 1992); In re U.S. Airways Group, Inc., 369 F.3d 806 (4th Cir. 2004); In re U.S. Brass Corp., 169 F.3d 957 (5th Cir. 1999); In re Continental Airlines, 91 F.3d 553 (3d Cir. 1996) (en banc).
discussed Cited as authority (rule) In Re Ual Corporation, Reorganized Debtors. Appeal Of: United Retired Pilots Benefit Protection Association
7th Cir. · 2006 · confidence medium
In re UNR Industries, Inc. 20 F.3d 766 (7th Cir.1994); In re Andreuccetti, 975 F.2d 413, 415, 417-19 (7th Cir.1992); In re U.S. Airways Group, Inc., 369 F.3d 806 (4th Cir.2004); In re U.S. Brass Corp., 169 F.3d 957 (5th Cir.1999); In re Continental Airlines, 91 F.3d 553 (3d Cir.1996) (en banc).
cited Cited as authority (rule) In Re Rybka
Bankr. N.D. Ill. · 2006 · confidence medium
In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992) (internal quotation omitted).
discussed Cited as authority (rule) United States v. Segal, Michael
7th Cir. · 2005 · confidence medium
Co., Inc., 3 F.3d 1043, 1048 (7th Cir.1993); see also UNR, 20 F.3d at 770 (“And it is the reliance interest engendered by the plan, coupled with the difficulty of reversing the critical transaction, that counsels against attempts to unwind things on appeal.”); In re Focus Media, Inc., 378 F.3d 916, 923 (9th Cir.2004) (a court should consider whether a case “presents transactions that are so complex or difficult to unwind that the doctrine [] would apply.”); In the Matter of Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992).
discussed Cited as authority (rule) United States v. Michael Segal v. M. Scott Michel, as Trustee of Mr. Segal's Forfeited Interests in Nnng and Its Subsidiaries and Affiliates, and Fireman's Fund Insurance Company
7th Cir. · 2005 · confidence medium
Co., Inc., 3 F.3d 1043, 1048 (7th Cir.1993); see also UNR, 20 F.3d at 770 ("And it is the reliance interest engendered by the plan, coupled with the difficulty of reversing the critical transaction, that counsels against attempts to unwind things on appeal."); In re Focus Media, Inc., 378 F.3d 916, 923 (9th Cir.2004) (a court should consider whether a case "presents transactions that are so complex or difficult to unwind that the doctrine [ ] would apply."); In the Matter of Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992). 18 While this equitable doctrine comes from bankruptcy principles, the s…
discussed Cited as authority (rule) In Re Commercial Loan Corp.
Bankr. N.D. Ill. · 2004 · confidence medium
Conclusions of Law A. Settlement Standards The pivotal question in approving a bankruptcy settlement is “whether the settlement is in the best interests of the estate.” In re Andreuccetti, 975 F.2d 413, 421 (7th Cir.1992); In re Energy Co-op., Inc., 886 F.2d 921, 927 (7th Cir.1989).
discussed Cited as authority (rule) Dowd & Dowd, Ltd. v. Gleason (In Re Gleason)
N.D. Ill. · 2004 · confidence medium
See In re 203 North LaSalle Street Partnership, 126 F.3d 955, 969 (7th Cir.1997) (“[T]he bankruptcy court’s finding that the plan was proposed in good faith is a finding of fact to which we owe deference.”); In re Andreuccetti, 975 F.2d 413, 419-420 (7th Cir. 1992) (bankruptcy court’s findings of fact are reviewed under clearly erroneous standard).
cited Cited as authority (rule) Donald Nangle v. Leslie Davis
8th Cir. BAP · 2003 · confidence medium
In re Marlar, 252 B.R. at 749 (citing In the Matter of Andreuccetti, 975 F.2d 413, 417 (7th Cir. 1992)).
cited Cited as authority (rule) Nangle v. Surratt-States (In Re Nangle)
8th Cir. BAP · 2003 · confidence medium
In re Marlar, 252 B.R. at 749 (citing In the Matter of Andreuccetti, 975 F.2d 413, 417 (7th Cir.1992)).
cited Cited as authority (rule) Smith v. Phoenix Bond & Indemnity
N.D. Ill. · 2002 · confidence medium
In the Matter of Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992).
discussed Cited as authority (rule) Williams v. Cheves
10th Cir. · 2002 · confidence medium
In other words, “[a] ‘person aggrieved’ by a bankruptcy order must demonstrate that the order diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.” In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992) (quotation omitted).
discussed Cited as authority (rule) Lopez v. Specialty Restaurants Corp. (In Re Lopez) (2×)
9th Cir. BAP · 2002 · confidence medium
Therefore, she alleged, she could show "a reasonable possibility of a surplus after satisfying all debts, and accordingly has shown a pecuniary interest.” See Matter of Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992).
discussed Cited as authority (rule) Ross Dworsky v. Canal Street Ltd. (2×) also: Cited "see"
8th Cir. BAP · 2001 · confidence medium
Adequate circumstances arise when a bankruptcy court order “diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.” In re Andreuccetti, 975 F.2d 413, 416 (7th Cir. 1992).
discussed Cited as authority (rule) Dworsky v. Canal Street Limited Partnership (In Re Canal Street Limited Partnership) (2×) also: Cited "see"
8th Cir. BAP · 2001 · confidence medium
Adequate circumstances arise when a bankruptcy court order “diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.” In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992).
discussed Cited as authority (rule) In Re: John Samuel Marlar, Debtor. Renee S. Williams, Trustee v. John Samuel Marlar
8th Cir. · 2001 · confidence medium
A debtor has standing to appeal if the bankruptcy court order "diminishes the person's property, increases the person’s burdens, or impairs the person’s rights.” In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992) (quotation omitted).
discussed Cited as authority (rule) Renee Williams v. John Marlar
8th Cir. · 2001 · confidence medium
A debtor has standing to appeal if the bankruptcy court order “diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights.” In re Andreuccetti, 975 F.2d 413, 416 (7th Cir. 1992) (quotation omitted).
discussed Cited as authority (rule) Spenlinhauer v. O'Donnell
1st Cir. · 2001 · confidence medium
In re Thompson, 965 F.2d at 1145-46 ; In re Colony Hill Associates (Kabro Associates v. Colony Hill Associates), 111 F.3d 269 , 273 (2d Cir.1997); In re Andreuccetti, 975 F.2d 413, 416-17 (7th Cir.1992). 6 .
discussed Cited as authority (rule) Lillie v. Rosania
10th Cir. · 2000 · signal: cf. · confidence medium
See § 158(d); State Gov’t Creditors’ Comm. for Property Damage Claims v. McKay, (In re Johns-Manville Corp. ), 920 F.2d 121, 126-27 (2d Cir. 1990) (discussing two-step determination of jurisdiction over bankruptcy appeals); cf. In re Andreuccetti , 975 F.2d 413, 419 (7th Cir. 1992) (reversing district court’s dismissal of bankruptcy appeal and affirming bankruptcy court’s final order on merits because appellate court “may affirm the judgment of a lower court on any nonwaived ground supported by the record” as long as the merits have been fully briefed and are capable of resolution…
examined Cited as authority (rule) Renee S. Williams v. John Samuel Marlar (3×) also: Cited "see"
8th Cir. BAP · 2000 · confidence medium
Ed. 2d 351 (1992)(describing Article III standing) with In re Andreuccetti, 975 F.2d 413, 416 (7th Cir. 1992)(describing bankruptcy standing).
discussed Cited as authority (rule) In Re P.R.T.C., Inc., Debtor. Duckor Spradling & Metzger v. Baum Trust (2×)
9th Cir. · 1999 · confidence medium
Corp.), 761 F.2d 1329, 1334 (9th Cir.1985) (“[W]e have adopted the ‘person aggrieved’ test as the appropriate standard for determining standing to appeal under the Code.”); In the Matter of Andreuccetti, 975 F.2d 413, 416-17 (7th Cir.1992) (“Its purpose is to insure that bankruptcy proceedings are not unreasonably delayed by protracted litigation by allowing only those persons whose interests are directly affected by a bankruptcy order to appeal.”) (citation and internal quotation marks omitted).
discussed Cited as authority (rule) In Re Drost (2×) also: Cited "see"
Bankr. N.D. Ind. · 1998 · confidence medium
Holloway Foundation, 36 F.3d 582, 585 (7th Cir.1994); Matter of Andreuccetti 975 F.2d 413, 416 (7th Cir.1992).
discussed Cited as authority (rule) Southern Pacific Transportation Co. v. Voluntary Purchasing Groups, Inc.
E.D. Tex. · 1998 · confidence medium
Co., Inc., 69 F.3d 746, 749 (5th Cir.), withdrawn in part, 74 F.3d 599 (5th Cir.1996); In re CFLC, Inc., 89 F.3d 673 , 675 (9th Cir.1996); In re Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992); International Trade Admin. v. Rensselaer Polytechnic Inst., 936 F.2d 744, 747 (2d Cir.1991); In re El San Juan Hotel, 809 F.2d 151, 154 (1st Cir.1987).
cited Cited as authority (rule) In the Matter of New Era, Inc., Appeals of New Era, Inc. And Phoenix Insurance Company
7th Cir. · 1998 · confidence medium
In re Andreuccetti, 975 F.2d 413, 416-17 (7th Cir.1992); Kane v. Johns-Manville Corp., 843 F.2d 636, 641-42 (2d Cir.1988).
examined Cited as authority (rule) In the Matter of 203 N. Lasalle Street Partnership, an Illinois Limited Partnership, Debtor-Appellee, Appeal Of: Bank of America Illinois (6×) also: Cited "see"
7th Cir. · 1997 · confidence medium
In re Andreuccetti, 975 F.2d 413, 419-20 (7th Cir.1992).
cited Cited as authority (rule) Matter of Rimsat, Ltd.
Bankr. N.D. Ind. · 1997 · confidence medium
Matter of Andreuccetti, 975 F.2d 413, 421 (7th Cir. 1992); In re American Reserve Corp., 841 F.2d 159 , 162 (7th Cir.1987).
cited Cited as authority (rule) Olsen v. Bank One, Rockford, NA (In Re Bruder)
N.D. Ill. · 1997 · confidence medium
Holloway Found., 36 F.3d 582 , 585 (7th Cir.1994) (quoting Matter of Andreuccetti, 975 F.2d 413, 416 (7th Cir.1992)).
discussed Cited as authority (rule) Krikor Dulgarian Trust v. Unified Management Corp. of Rhode Island (In Re Peaberry's Ltd.)
1st Cir. BAP · 1997 · signal: cf. · confidence medium
Cf. In re Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992) (discussing equitable considerations pertinent to mootness concerns regarding appellate review of confirmation orders), cited in Institut Pasteur, et al, v. Cambridge Biotech Corp. (In re Cambridge Biotech), 104 F.3d 489, 491 (1st Cir.1997); Rochman v. Northeast Utilities Service Group (In re Public Service Company of New Hampshire), 963 F.2d 469 (1st Cir.1992) (same). 9 Conclusion For the reasons set forth above, we conclude that the bankruptcy court’s order denying Krikor Bulgarian’s motion seeking payment of all pre-assumption lea…
discussed Cited as authority (rule) Square D Co. v. Fastrak Softworks, Inc.
7th Cir. · 1997 · confidence medium
The issue of whether a claim for specific injunctive relief is moot is a fact-specific one, see In Re Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992), that requires the court to assess not only the adjudicative facts of the case but also the probable impact of the requested relief on that factual situation.
discussed Cited as authority (rule) Square D Company v. Fastrak Softworks, Incorporated
7th Cir. · 1997 · confidence medium
The issue of whether a claim for specific injunctive relief is moot is a fact-specific one, see In Re Andreuccetti, 975 F.2d 413, 418 (7th Cir.1992), that requires the court to assess not only the adjudicative facts of the case but also the probable impact of the requested relief on that factual situation.
discussed Cited as authority (rule) American Network Leasing, Inc. v. APEX Pharmaceuticals, Inc. (In Re APEX Pharmaceuticals, Inc.)
N.D. Ind. · 1996 · confidence medium
In deciding whether to modify such a plan, the test is whether “implementation of the plan has created, extinguished or modified rights, particularly of persons not before the court, to such an extent that effective judicial relief is no longer practically available.” In re Andreuccetti 975 F.2d 413, 418 (7th Cir.1992) (quoting Central States, Southeast and Southwest Areas Pension Fund v. Central Transport, Inc., 841 F.2d 92, 96 (4th Cir.1988)).
Retrieving the full opinion text from the archive…
27 Collier bankr.cas.2d 1157, Bankr. L. Rep. P 74,903 in the Matter of Joseph Andreuccetti and Noemi Andreuccetti, Debtors-Appellants
91-1947.
Court of Appeals for the Seventh Circuit.
Sep 18, 1992.
975 F.2d 413
1992 U.S. App. LEXIS 22727
1992 WL 228882
Marc A. Primack, Rooks, Pitts & Poust, Chicago, Ill., Martin A. Diestler, Rooks, Pitts & Poust, Wheaton, Ill., for Household Bank F.S.B., William T. McGrath, Frank Pawlak, argued, Wilson & Mcllvaine, Chicago, Ill., for First Nat. Bank of Cicero., Abraham Brustein, argued, Burke, Smith & Williams, John B. Kalish, John E. Gie-rum, Kalish & Colleagues, Chicago, Ill., for Joseph and Noemi Andreuccetti.
Posner, Easterbrook, Ripple.
Cited by 132 opinions  |  Published
RIPPLE, Circuit Judge.

Joseph and Noemi Andreuccetti (collectively “the Andreuccettis”) appeal from an order dismissing their appeal from the confirmation of the reorganization plan in their Chapter 11 bankruptcy. The district court dismissed their appeal on alternative grounds, concluding, first, that the Andre-uccettis’ bankruptcy estate was so insolvent that they were without standing to bring the appeal, and second, that the appeal was moot. While we agree with the Andreuccettis that the district court erred in its application of the standing and mootness doctrines, we nonetheless find merit-less their challenges to the reorganization plan. Accordingly, we reverse the judgment of the district court but nevertheless[*415] direct it to enter judgment affirming the bankruptcy court.

I

BACKGROUND

A. Facts

In 1982, Mr. Andreuccetti formed a partnership with two other persons to develop a condominium project in Illinois. To finance the project, he borrowed several million dollars from American Heritage Savings and Loan (American Heritage) and appellee First National Bank of Cicero (Cicero). The condominium project was not completed, and in late 1983 and early 1984 the banks filed actions in Illinois state court to foreclose and to enforce the loans against Mr. Andreuccetti. Mr. Andreuccetti counterclaimed against the banks, alleging fraud, conspiracy, and misdirection of loan funds. He sought more than $1.2 million in compensatory damages and more than $3 million in punitive damages. Subsequently, American Heritage became insolvent, and appellee Household Bank, fsb (Household), purchased certain assets and liabilities of American Heritage, including Mr. Andreuccetti’s notes and the state court foreclosure action. Household succeeded American Heritage as a party in the state court litigation.

B. Bankruptcy Court Proceedings

In August 1984, a few months after the foreclosure suits were filed, Cicero filed an involuntary Chapter 7 bankruptcy petition against the Andreuecettis. In 1989, this case was converted into a Chapter 11 reorganization, but the trustee still remained in place. The Consolidated Disclosure Statement filed by the Andreuecettis and the banks indicates that, in the spring of 1990, the Andreuecettis’ total liabilities were estimated at around $3.5 million, approximately $3.25 million of which was owed to Cicero and Household. The statement also indicates that the Andreuecettis had nonexempt real and personal property worth approximately $114,000. Additional assets listed in the statement were the counterclaims pending against the banks. During the course of the bankruptcy proceedings, the trustee sold the condominium property for $1,125 million, and these proceeds were held in an escrow account, subject to further court order. In 1990, the AndreucCet-tis filed á plan for reorganization, and Household and Cicero jointly filed a competing plan. The Andreuecettis’ plan provided for payment of unsecured creditor claims through the recovery, if any, from the state court litigation against the banks. Under the plan, the creditors could receive up to 200 percent of their allowed claims, depending on the results obtained in the litigation. However, they would receive nothing if the lawsuit were unsuccessful. The reorganization plan of the banks was more complex. The most salient features were: (1) the trustee would dismiss all claims against Cicero in the state court litigation, and he would release the punitive damages claim against Household, but the trustee would continue to be able to pursue a claim for compensatory damages against Household; (2) Household would receive the remaining proceeds from the sale of the condominium property; (3) Household would pay, or disburse from the proceeds of the sale, additional administrative claims for compensation to the trustee and his counsel, up to approximately $41,000; and (4) Cicero would contribute assets to the bankruptcy estate, including cash, worth approximately $230,000.

The bankruptcy court ultimately confirmed the banks’ plan, and the record indicates that a portion of it has been implemented. Household has received the remaining proceeds of the sale and, under the plan, the trustee and his counsel have been paid around $41,000 as compensation. The trustee and Household have entered into a covenant not to sue on the punitive damages claim, although the trustee has the right to rescind the agreement if the reorganization plan is reversed on appeal. Likewise, the trustee and Cicero have agreed to dismiss the entire counterclaim against Cicero, although that agreement also allows the trustee to reinstate the claim if the reorganization plan is overturned.

[*416] C. District Court Proceedings

The Andreuccettis appealed to the district court, raising several challenges to the confirmation of the plan. In particular they alleged: (1) that the plan did not provide for their exemption rights; (2) that the plan inadequately treated administrative claims, particularly those of their attorneys, in violation of 11 U.S.C. §§ 1123 and 1129(a)(9); (3) that the banks did not propose the plan in good faith, in violation of 11 U.S.C. § 1129(a)(3); (4) that the plan impaired their rights in the state court lawsuits without giving them an opportunity to approve it, in violation of 11 U.S.C, § 1129(a)(8); and (5) that the bankruptcy court did not adequately evaluate the propriety of settling the state court law suits. In response, Household filed a motion to dismiss, arguing that the Andreuccettis had no interest in the appeal that would provide them standing to pursue it and, alternatively, that the appeal was moot.

The district court agreed with Household and dismissed the appeal in a short opinion. In re Andreuccetti, 127 B.R. 185 (N.D.Ill.1991). The court declined to reach the merits of the Andreuccettis’ arguments, concluding instead that the Andreuccettis were “not sufficiently affected by the confirmation of the reorganization plan to bring this appeal,” because the amount of debt was so great that they stood no realistic chance of emerging from bankruptcy with surplus assets. Id. at 186. In addition, the court determined that the Andreuccettis lacked standing to pursue arguments related to the administrative claims of their attorneys. Id. As an alternative ground for dismissal, the court held that “several factors suggest that the appeal should be considered moot.” Id. The factors that the court cited in support of mootness were that “[significant steps have been taken since entry of the confirmation order to implement the reorganization plan,” id., and that approximately seven years had passed since the time of filing and the confirmation of the reorganization plan, id. at 186-87.

II

ANALYSIS

On appeal before this court, the Andreuc-cettis contend that the district court improperly determined both that they lacked standing to bring this appeal and that the appeal was moot. Household argues that if the district court misapplied the standing and mootness doctrines in this case, the Andreuccettis’ appeal is nevertheless merit-less and we should affirm the confirmation order of the bankruptcy court. We shall deal with each of these issues in turn.

A. Standing

As we have recently noted:

In order to appeal a bankruptcy court’s order, a litigant must qualify as a "person aggrieved” by the order. In re El San Juan Hotel, 809 F.2d 151, 154 (1st Cir.1987). A “person aggrieved” by a bankruptcy order must demonstrate that the order diminishes the person’s property, increases the person’s burdens, or impairs the person’s rights. See In re Fondiller, 707 F.2d 441, 442 (9th Cir.1983).

Matter of DuPage Boiler Works, Inc., 965 F.2d 296, 297 (7th Cir.1992). Generally speaking, “[o]nly those persons who are directly and adversely affected pecuniarily by an order of the bankruptcy court have been held to have standing to appeal that order.” Matter of Fondiller, 707 F.2d at 442; see also In re Thompson, 965 F.2d 1136, 1142 n. 9 (1st Cir.1992); Holmes v. Silver Wings Aviation, Inc., 881 F.2d 939, 940 (10th Cir.1989); Kane v. Johns-Manville Corp., 843 F.2d 636, 641 (2d Cir.1988); In re Cosmopolitan Aviation Corp., 763 F.2d 507, 513 (2d Cir.), cert. denied, 474 U.S. 1032, 106 S.Ct. 593, 88 L.Ed.2d 573 (1985); 1 Lawrence P. King et al., Collier on Bankruptcy 113.03[5] (15th ed. 1992). This “person aggrieved” requirement is more exacting than the requirements for general Article III standing. Kane, 843 F.2d at 642 n. 2; Matter of Carbide Cutoff, Inc., 703 F.2d 259, 264 (7th Cir.1983). Its purpose is to insure “that bankruptcy proceedings are not unreasonably delayed by protracted litigation by allowing only those[*417] persons whose interests are directly affected by a bankruptcy order to appeal.” Du-Page Boiler Works, Inc., 965 F.2d at 297.

The banks assert that the Andreuc-cettis lack standing. First, emphasizing the requirement that the interest at stake be “directly” affected, see Fondiller, 707 F.2d at 442, Cicero claims that a direct injury to the Andreuccettis is not present here because there is no guarantee that pursuing the state court litigation would provide them a surplus after emerging from bankruptcy. Cicero Br. at 18. As an alternative argument, both banks cite the rule that a “hopelessly insolvent debtor” does not have standing to appeal orders affecting the size of the estate. If a debtor can be so characterized, such an order would not diminish the debtor’s property, increase his burdens, or detrimentally affect his rights. El San Juan Hotel, 809 F.2d at 154-55; Fondiller, 707 F.2d at 442; see also Matter of UNR Indus., Inc., 725 F.2d 1111, 1120 (7th Cir.1984) (The debtor “will be able to appeal to us from the order adopting the plan ... assuming it is not so hopelessly insolvent at that point that it is indifferent to the terms of the reorganization.”). Consequently, the debtor “has no pecuniary interest in the distribution of his assets among his creditors” and thus has no basis for standing. Willemain v. Kivitz, 764 F.2d 1019, 1022 (4th Cir.1985). The banks then attempt to bring the Andreuc-cettis within this rule by arguing that the size of the debt owed and the contingencies of litigating the state court claims indicate that the Andreuccettis have no realistic chance of recovering a surplus in this situation. The Andreuccettis, the banks submit, were therefore “hopelessly insolvent,” and without any standing to appeal.

We cannot accept the banks’ contentions. The state court litigation is against the two creditors who together hold the vast majority of the Andreuccettis’ debt. The non-bank claims against the Andreuc-cettis are small in comparison. The outcome of this litigation could potentially have a huge effect on the liabilities of the Andreuccettis and could give them a substantial surplus upon emerging from bankruptcy. Moreover, the compensatory and punitive damages claims in the state court counterclaims, if they had been litigated and not settled, as the Andreuccettis urge, could make it possible for the Andreuccet-tis to recover an amount sufficient to discharge their debts and also provide them with a surplus following bankruptcy. The reorganization plan effectively extinguishes that chance by settling the suits for less than what would be needed to create a surplus. The Andreuccettis’ submission to the district court included allegations that the bankruptcy court failed to accord them sufficient opportunity to establish that the creditors’ plan was inadequate and that the bankruptcy court’s methodology in assessing the value of the state court lawsuits was flawed. Thus, the Andreuccettis’ interest in gaining the possible surplus has been affected by the confirmation of the plan, and they possess a pecuniary interest that could be directly and adversely affected by the confirmation order. This alleged injury is sufficiently direct to allow for standing. [1] We cannot hold that the Andre-uccettis’ contentions with respect to the bankruptcy court’s treatment of these state counterclaims are so unmeritorious as to justify terminating the appeal without reaching the merits. [2]

B. Mootness

As an alternative ground for dismissal, the district court held that “several[*418] factors” in the case “suggest that the appeal should be considered moot.” In re Andreuccetti, 127 B.R. at 186. As support for this conclusion, the court noted that “significant steps have been taken since entry of the confirmation order to implement the reorganization plan,” including payments to the trustee and his attorneys, as well as transfers of money to Household. The district court believed that a finding of mootness was warranted because of the substantial amount of time that the case had spent in the bankruptcy court and the “extensive attention” that it had received there. Id. at 186-87 (quoting Dist.Ct. R.20, Household’s Br. for Appellee and in Supp. of Mot. to Dismiss at 11).

In concluding that the appeal was moot, the district court relied on a standard for mootness in bankruptcy proceedings that other circuits have articulated in a number of cases. See, e.g., In re Club Associates, 956 F.2d 1065, 1069 (11th Cir.1992); Miami Center Ltd. Partnership v. Bank of New York, 838 F.2d 1547, 1554-55 (11th Cir.), cert. denied, 488 U.S. 823, 109 S.Ct. 69, 102 L.Ed.2d 46 (1988); In re AOV Indus., Inc., 792 F.2d 1140, 1147-50 (D.C.Cir.1986). Under this standard, a court may consider a challenge to a reorganization plan moot and unreviewable “when implementation of the plan has created, extinguished or modified rights, particularly of persons not before the court, to such an extent that effective judicial relief is no longer practically available.” Central States, Southeast and Southwest Areas Pension Fund v. Central Transport, Inc., 841 F.2d 92, 96 (4th Cir.1988). In applying this mootness rule in the context of a reorganization case, “the court may consider the virtues of finality, the passage of time, whether the plan has been implemented and whether it has been substantially consummated, and whether there has been a comprehensive change in circumstances.” Miami Center Ltd. Partnership, 838 F.2d at 1555 (citing AOV Indus., Inc., 792 F.2d at 1148-49). In addition, the court may consider whether, within the facts of the case, it would be highly inequitable to reverse the bankruptcy court’s order. Matter of Crystal Oil Co., 854 F.2d 79, 81-82 (5th Cir.1988); In re Roberts Farms, Inc., 652 F.2d 793, 798 (9th Cir.1981). As the Eleventh Circuit noted

[t]he test for mootness reflects a court’s concern for striking the proper balance between the equitable considerations of finality and good faith reliance on a judgment and the competing interests that underlie the right of a party to seek review of a bankruptcy court order adversely affecting him.

Club Associates, 956 F.2d at 1065. Consequently, when determining whether an appeal has been rendered moot, “the reviewing court must ‘scrutinize each individual claim, testing the feasibility of granting relief against the potential impact on the reorganization scheme as a whole.'" In re Public Service Co. of New Hampshire, 963 F.2d 469, 473 (1st Cir.1992) (quoting AOV Indus., Inc., 792 F.2d at 1148), petition for cert. filed, 61 U.S.L.W. 3059 (U.S. June 29, 1992) (No. 92-14). That is, “[t]he court should reach a determination upon close consideration of the relief sought in light of the facts of the particular case.” Central Transport, 841 F.2d at 96; see also In re Texaco, Inc., 92 B.R. 38, 46-47 (S.D.N.Y. 1988).

We believe that the district court did not analyze properly the Andreuccettis’ appeal prior to declaring it moot. Consequently, we must reverse its decision dismissing the appeal on that ground. Here, the Andreuccettis have several discrete challenges to the bankruptcy court’s confirmation of the reorganization plan, including that it improperly treated certain claims and interests and that it improperly included in the reorganization plan the settlement of the state court litigation. The district court concluded summarily that these claims were moot because a portion of the plan had been implemented and the ease had spent a substantial period of time in the bankruptcy courts. However, as we have just noted, determining whether an appeal has become moot requires a fact-specific inquiry into the nature of the relief sought, and the effects that relief could have on the overall reorganization plan. The district court’s order does not reflect[*419] this careful, individualized assessment of each claim to determine if judicial relief is available as a practical matter. Moreover, after our own examination of the record, we are not convinced that the facts of this case clearly indicate that these claims are moot. Although a portion of the reorganization plan appears to have been completed, other aspects of it may remain undone. For example, the record suggests that none of the creditors of the estate, other than Household and the trustee and his counsel, has been paid. Household and Cicero, the parties who are probably most affected by the order, are currently before the court. In addition, the state court litigation against Household appears to remain alive, and the settlement agreements between the trustee and the banks specifically allow the settled claims to be reinstated if the reorganization plan is overturned on appeal. Although the fact that a court could undo a completed act may not necessarily defeat the conclusion that a matter is moot, see Miami Center Ltd. Partnership, 838 F.2d at 1555 n. 7, it is certainly a relevant factor for a court determining whether effective relief on a claim can be granted. Texaco, Inc., 92 B.R. at 50 n. 15. In short, the present record cannot support the district court’s conclusory determination.

C. The Merits

Household asserts that, even if the district court had erred in concluding that the Andreuccettis did not have standing to bring the appeal and that the appeal was moot, the bankruptcy court’s confirmation of the plan should be affirmed because the appeal is without merit. We agree. As an appellate court, we may affirm the judgment of a lower court on any non-waived ground supported by the record. See McCarthy v. Kemper Life Ins. Cos., 924 F.2d 683, 686 n. 1 (7th Cir.1991); see also In re Siriani, 967 F.2d 302 (9th Cir. 1992) (applying rule in bankruptcy context); In re Public Serv. Co. of New Hampshire, 879 F.2d 987, 989 (1st Cir.1989) (per curiam) (same). Several factors in this case make it clear that we appropriately may resolve the merits of the Andreuccettis’ case. First, Household has presented the merits to us in its brief, and the Andreuccettis have had a fair opportunity to respond to its arguments. [3] We also have before us the briefs that the parties submitted on the matter to the district court. Finally, after examining the record, we conclude that the issues in the Andreuccettis’ appeal are sufficiently straightforward to be capable of resolution at this point. See In re Clark, 927 F.2d 793, 796-97 (4th Cir.1991) (deciding on appeal issue of bankruptcy trustee’s ability to bring motion, despite the fact that the district court had not addressed the matter).

On appeal before the district court, the Andreuccettis raised five challenges to the confirmation of the reorganization plan. They alleged: (1) that the plan did not provide for their exemption rights; (2) that the plan improperly treated administrative claims, particularly those of their attorneys, in violation of 11 U.S.C. §§ 1123 and 1129(a)(9); (3) that the plan was not proposed in good faith, in violation of 11 U.S.C. § 1129(a)(3); (4) that the plan impaired the Andreuccettis’ interest in the state court lawsuits without giving them a right to vote, in violation of 11 U.S.C. § 1129(a)(8); and (5) that the bankruptcy court did not adequately evaluate the propriety of settling the state court law suits. DistCt. R.13, Br. for Appellant at 6-10. The standard for our review of these contentions is well-established. On appeal, this court exercises de novo review of the district court’s and the bankruptcy court’s conclusions of law. Matter of Love, 957 F.2d 1350, 1354 (7th Cir.1992); Matter of Seibert, 914 F.2d 102, 104-05 (7th Cir.1990). Findings of fact made by the bankruptcy court are reviewed under a clearly errone[*420] ous standard. Matter of Bonnett, 895 F.2d 1155, 1157 (7th Cir.1989); First Wisconsin Nat’l Bank of Milwaukee v. Federal Land Bank of St. Paul, 849 F.2d 284, 286 (7th Cir.1988).

The first three of the Andreuccettis’ contentions do not merit extended discussion. First, with regard to the argument that the plan did not provide for their exemption rights, the Andreuccettis do not identify in their briefs either what these exemption rights are or how they were impaired. This argument is so underdeveloped that it cannot be evaluated, and we therefore must reject it. Second, the argument that the plan improperly treated administrative claims is also fatally defective. Here, the Andreuccettis argue that the reorganization plan limited the rights of holders of administrative claims. However, the Andreuccettis themselves do not claim that they hold any of these claims, nor do they assert that they were otherwise adversely affected by the plan’s treatment of these claims. Instead, the Andreuccettis attempt to assert the rights of other persons in order to invalidate the plan. As a general rule, a party’s desire to protect the rights of others does not permit a court to adjudicate a claim. Matter of Deist Forest Prods., Inc., 850 F.2d 340, 341 (7th Cir. 1988); Kane, 843 F.2d at 644-45; In re Umpqua Shopping Ctr., Inc., Ill B.R. 303, 305 (Bankr. 9th Cir.1990); see also In re Evans Prods. Co., 65 B.R. 870, 874 (S.D.Fla.1986) (debtors lack standing to raise the rights of wrongly classified creditors as a means to attack the overall reorganization plan). The Andreuccettis make no argument why the general rule against third party standing should be relaxed’ in this case, and we therefore conclude that they lack standing to challenge the plan’s treatment of administrative claims. See Holywell Corp. v. Bank of New York, 59 B.R. 340, 349-50 (S.D.Fla.1986). Third, with regard to the claim that the reorganization plan was not proposed in good faith, we note that the bankruptcy court made explicit findings on the question, and it determined that the plan had been proposed in good faith. R.4 at 1; Tr. 9 at 68. This finding is one of fact, which we will not overturn unless it is clearly erroneous. Covey v. Commercial Nat’l Bank of Peoria, 960 F.2d 657, 662 (7th Cir.1992); Matter of Love, 957 F.2d at 1354; Hanson v. First Bank of South Dakota, N.A., 828 F.2d 1310, 1315 (8th Cir.1987). The Andreuccettis challenge this finding of good faith by claiming that the sole evidence supporting this determination was the trustee’s testimony that he was not aware of any bad faith by anyone involved in the case. Tr. 9 at 68. We note, however, that additional factors are present in the record to support the bankruptcy court’s finding, including its personal assessment of the conduct of the parties over the course of the bankruptcy proceedings, Tr. 9 at 68, and the fact that the plan proposed by the banks received overwhelming support from the Andreuccettis’ creditors. The bankruptcy court committed no error in concluding that the plan was proposed in good faith. See Matter of Madison Hotel Associates, 749 F.2d 410, 425 (7th Cir.1984) (In determining “good faith" the “important point of inquiry is the plan itself and whether such plan will fairly achieve a result consistent with the objectives and purposes of the Bankruptcy Code.”).

The Andreuccettis’ final two challenges to the confirmation of the bankruptcy reorganization plan ought to be analyzed together. The Andreuccettis challenge the confirmation of the plan on the ground that it impaired their interest in the state court lawsuits, and that, under 11 U.S.C. § 1124 and 11 U.S.C. § 1129(a)(8), they should have had an opportunity to approve it. Finally, the Andreuccettis claim that the bankruptcy court erred because it confirmed the plan despite the fact that it “failed to sufficiently discharge its duty of determining the propriety of” settling the state court lawsuits. Dist.Ct. R.13 at 10. In particular, they allege that the bankruptcy court failed to examine certain relevant factors when determining if settlement was appropriate. Both of these contentions turn on the bankruptcy court’s decision to accept the settlement of the state court litigation. “The benchmark for determining the propriety of a bankruptcy[*421] settlement is whether the settlement is in the best interests of the estate.” Matter of Energy Coop., Inc., 886 F.2d 921, 927 (7th Cir.1989). “Central to the bankruptcy judge’s determination is a comparison of the settlement’s terms with the litigation’s probable costs and probable benefits. Among the factors the bankruptcy judge should consider in his analysis are the litigation’s probability of success, the litigation’s complexity, and the litigation’s attendant expense, inconvenience, and delay.” In re American Reserve Corp., 841 F.2d 159, 161-62 (7th Cir.1987) (citations omitted). A bankruptcy court’s approval of a settlement of a claim will not be overturned unless it was an abuse of discretion. Id. at 162; Energy Coop., Inc., 886 F.2d at 926.

We believe that the bankruptcy court properly exercised its discretion in approving the settlement of the state court lawsuits. The bankruptcy judge was of the view that the settlement represented a realistic assessment of the current value of the state litigation. Cf. Matter of Central Ice Cream Co., 836 F.2d 1068, 1072 n. 3 (7th Cir.1987). In reaching this evaluation, the bankruptcy court was openly concerned with the possibility that Illinois law would not allow the Andreuccettis to recover any punitive damages from Household, the successor of the original alleged tortfeasor, American Heritage. Tr. 9 at 8, 69. If this estimation was correct, the possible recovery for the Andreuccettis may have been even less. Indeed, there was a significant basis for the bankruptcy court’s view. See Mattyasovszky v. West Towns Bus Co., 61 Ill.2d 31, 330 N.E.2d 509, 511-12 (1975) (Justifications for the imposition of punitive damages are sharply diminished in those cases in which liability is imposed vicariously.); Ballard v. Bird, 84 Ill.App.3d 157, 39 Ill.Dec. 553, 556, 405 N.E.2d 1, 3 (1980) (Exemplary damages are awarded primarily to punish the offender and discourage similar offenses and these punitive and admonitory justifications are sharply diminished where liability is imposed vicariously.). See also AMPAT/Midwest, Inc. v. Illinois Tool Works, Inc., 896 F.2d 1035, 1043 (7th Cir.1990). In addition, the creditors of the Andreuccettis overwhelmingly approved the banks’ reorganization plan. At several points in the transcript, the court stated that it felt constrained to follow the wishes of the creditors, particularly because the alternative plan offered by the Andreuccettis would have provided the creditors no guarantee that they would recover any portion of their claims. Tr. 9 at 34-35, 70-71. The court’s conclusion, under the circumstances of this case, was certainly on solid ground. When offered double or nothing by the Andreuccettis, the creditors were willing to take a settlement that gave them less than the face value of their claims. The estimation of the value of the Andreuccettis’ claim is therefore a credible evaluation of its worth. Cf. Matter of Central Ice Cream Co., 836 F.2d 1068, 1072-73 n. 3 (7th Cir.1987). (“Self-interest concentrates the mind, and people who must back their beliefs with their purses are more likely to assess the value of the judgment accurately than are people who simply seek to make argument.”) Indeed, the Andreuccettis presented no evidence or testimony at the confirmation hearing to challenge this valuation. The bankruptcy court properly analyzed the proposed settlement and did not abuse its discretion in concluding that it was in the best interests of the estate. American Reserve Corp., 841 F.2d at 161.

Because we believe that the bankruptcy court was correct in determining that the state suits were worth a great deal less than the amount necessary to create a residuum for the Andreuccettis, there is no necessity to determine whether the bankruptcy court was correct in its determination that the Andreuccettis had no right to vote on the plan. Cf. In re A.H. Robins Co., 880 F.2d 694, 697-98 (4th Cir.) (applying harmless error analysis to challenge to voting procedures when the creditors overwhelmingly approved the plan), cert. denied, 493 U.S. 959, 110 S.Ct. 376, 377, 107 L.Ed.2d 362 (1989); Kane, 843 F.2d at 646-48 (same).

Conclusion

For the foregoing reasons we reverse the decision of the district court dismissing the[*422] Andreuccettis’ appeal on the basis of mootness and lack of standing. However, we remand the case to the district court with directions to confirm the reorganization plan. The appellees may recover their costs in this court.

Reversed and Remanded With DiRECTIONS.

1

. See In re Goodwin’s Discount Furniture, Inc., 16 B.R. 885, 888 (Bankr. 1st Cir.1982) (Debtor would have standing on appeal if “the order appealed from would directly and adversely affect the possibility of residual assets being available to the Debtor.”); see also Kapp v. Naturelle, Inc., 611 F.2d 703, 706-07 (8th Cir.1979) ("[W]hen it appears that, if the contested claims are disallowed, there may be a surplus of assets to be returned to the bankrupt, the bankrupt is considered to have standing to contest the claims.”) (emphasis supplied); Willemain v. Kiv-itz, 764 F.2d 1019, 1022 (4th Cir.1985) (quoting Kapp and applying the quoted language to question of whether a debtor had standing to bring an appeal).

2

. We note that, upon reaching the merits of this appeal, we shall be confronted with the distinct issue of whether the Andreuccettis had standing before the bankruptcy court to object to the administrative claims.

3

. We note that in their reply brief the Andreuc-cettis did not attempt directly to respond to Household’s arguments concerning the merits of the appeal. Instead, they argue that we should remand the case to the district court to obtain its views on the merits. These issues were squarely presented in Household’s brief, and the Andreuccettis had a full opportunity to address them. The fact that they made a decision, tactical or otherwise, not to do so should not stop us from deciding these issues here.