When a debtor seeks permission to use cash collateral, “operating expenses” can be approved more readily than other uses. In this context, the term “operating expenses” is tied to the collateral. I use it as a shortcut for the more precise phrase: “ordinary, necessary expenses required to maintain and operate the Property [the underlying collateral] to preserve its value.” In re Willowood East Apartments of Indianapolis, 114 B.R. 138, 143 (Bankr. S.D. Ohio 1990).
- All payroll and normal and reasonable employee expenses, including post-petition payroll taxes for employees located at the Property;
- Utilities, equipment leases, insurance and similar expenses necessary to operate the Property;
- Reasonable fees under management and marketing agreements;
- Ordinary and necessary repairs and maintenance to permit the continued use and operation of the Property, but not, without consent of [the secured creditor], any expenditure generally considered to be a capital improvement;
- Ordinary advertising or marketing expenses;
- Taxes and governmental charges accruing after the filing of the Petition herein attributable to the Property;
- Reasonable bookkeeping and accounting fees to the entity chosen by the Debtor to perform these services for the Property; and
- Other charges incurred after the filing of the Petition which are necessary to conduct the Debtor’s normal business operations.