How have the courts interpreted the meaning of section 541(a) of the Bankruptcy Code?

As with all statutory construction issues, we start with the statutory language. We begin by looking at 541 which defines property of the estate. Under 541(a), the commencement of a case under the Bankruptcy Code creates an estate. Although the estate may acquire property after the commencement of the case, see 541(a)(6) and (7), estate property remains distinct from the debtor's property. See Smith v. Kennedy (In re Smith), 235 F.3d 472, 478 (9th Cir.2000). Under 541(a)(6), earnings from services performed by an individual debtor after the commencement of the case are the debtor's property which are excluded from property of the estate.