The First Circuit’s decision in Malley v. Agin highlights an ongoing conflict among the federal circuit courts regarding the scope, nature and extent of the bankruptcy court’s equitable powers under §105(a) of the Bankruptcy Code. While the issue cries out for a definitive ruling by the U.S. Supreme Court, it is uncertain when and if one of these cases will reach the high court because the dollar amounts involved are often modest, as this case illustrates.