The Lionel case has long stood as the standard bearer for asset sales in bankruptcy that are outside of the ordinary course of business and outside of a plan of reorganization. The big auto cases later refined the analysis. The decision in Boston Generating1 confirms the option of selling substantially all of a debtor’s assets pursuant to a pre-negotiated sale, outside of a plan, and presented to the court within 48 hours of a Chapter 11 filing. Provided, that is, that
(i) there is a good business reason for proceeding with a sale rather than a plan,
