The bankruptcy trustee overseeing the liquidation of Bernard Madoff's investment advisory firm will ask a court to decide how much the imprisoned swindler's victims should recover, including those seeking profits reflected on their faked account statements.

In a Thursday filing with the U.S. Bankruptcy Court in Manhattan, trustee Irving Picard said he wanted to determine how much "net equity" each customer had at Bernard L. Madoff Investment Securities LLC, the epicenter of an estimated $65 billion Ponzi scheme.

He said this sum would reflect a "cash in/cash out" approach, where net equity equals the amounts of cash that customers deposit, minus amounts withdrawn.

That approach would disappoint many Madoff victims.

Some have proposed valuing their stakes based on amounts reflected on their November 30, 2008, account statements. Such amounts may be illusory if the statements were based on transactions that Madoff's firm claimed to make but never did.