4 Collier on Bankruptcy P 510.05
Summary
Section 510(c) permits the court to subordinate claims under principles of equitable subordination.1 This subsection was essentially a codification of prior case law2
with further development of the principles of equitable subordination left to the courts.3
Under subsection (c)(1), claims may be subordinated to claims, and interests may be subordinated to interests, but claims may not be subordinated to interests.4