Sales of assets under a confirmed plan in a Chapter 11 bankruptcy are exempt from transfer taxes. Many courts had interpreted the exemption broadly and applied the exemption to sales that occur during a bankruptcy, but before a Chapter 11 plan had actually been confirmed, so long as the sale was generally in furtherance of the ultimate goals of bankruptcy. The Supreme Court imposed a strict interpretation of the statute stating that transfer taxes must be paid unless the sale actually occurs pursuant to an already confirmed plan. Florida Department of Revenue v. Picca Dilly Cafeterias, Inc., 554 U.S. _____ (2008). This ruling may have a significant impact in states where there are higher transfer taxes since many sales in bankruptcy may occur early in the case before a plan is confirmed.