answer:More details are needed here. If there is a debate about whether the services were rendered, then it’s not a demand for earned commissions to be returned but a debate about whether the commissions were actually earned. However, if payment has been released to the salesperson, then the employer would probably have to initiate suite against the employee (using those terms loosely). Bankruptcy of the employer don’t require return of anything to the estate legally paid. Employee wages and commissions earned within 90 days of the bankruptcy filing are entitled to a high bankruptcy priority. Anything else is treated as an unsecured creditor claim.