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§ 541(d)

Rachel, In re--Browner v. Rachel

Ruling
Debtor's former spouse was entitled to prevail as a constructive trust was impressed upon theshare of equity in real property awarded to the former spouse, such that the property did notbecome part of the debtor's bankruptcy estate. (Bankr. S.D. Ohio)
Issue(s)
Property of the Estate; Estate Acquires Same Interest Held by Debtor.

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Consumer opinion summary, case decided on June 03, 2024 , LexisNexis #0824-016

Genesis Global Holdco, LLC v. Genesis Global Capital, LLC

Ruling
Creditor did not have a security interest in bitcoin trust shares held by debtor that wereproperty of the estate and never transferred or pledged to creditor. (Bankr. S.D.N.Y.)
Issue(s)
Property of the Estate; Estate Acquires Same Interest Held by Debtor.

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Commercial opinion summary, case decided on February 07, 2024 , LexisNexis #0324-087

Olson, In re--Kurtz v. Olson

Ruling
Debtor's bare legal interest in property post-divorce was excluded from property of the estate. (Bankr. D. Idaho)
Issue(s)
Property of the Estate; Estate Acquires Same Interest Held by Debtor.

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Consumer opinion summary, case decided on June 02, 2023 , LexisNexis #0723-087

Specialty's Café & Bakery, Inc., In re--Brady v. United States, SBA

Ruling
Proceeds of Paycheck Protection Program loan that was rescinded by debtor were subject to aresulting trust and not property of the estate. (Bankr. N.D. Cal.)
Issue(s)
Property of the Estate; Estate Acquires Same Interest Held by Debtor.

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Commercial opinion summary, case decided on February 02, 2022 , LexisNexis #0322-064

Short, In re--Miller v. Short

Ruling
Trustee could recognize a constructive trust on property held in the name of non-debtorspouse if imposed under state law prior to petition date. (Bankr. E.D. Mich.)
Issue(s)
Property of the Estate; Estate Acquires Same Interest Held by Debtor.

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Consumer opinion summary, case decided on February 16, 2021 , LexisNexis #0321-086

LaForce, In re

Ruling
Spouse's equitable interest in marital property was not property of debtor's bankruptcy estate as the marital property was held in constructive trust for the spouse's benefit. (Bankr. S.D. Ala.)
Issue(s)
Property of the Estate; Estate Acquires Same Interest Held by Debtor.

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Consumer opinion summary, case decided on September 06, 2017 , LexisNexis #1017-045

In re Christakos

Ruling
Postpetition child support payments were not property of the estate.
Issue(s)
Is postpetition child support property of the estate?

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Consumer opinion summary, case decided on June 20, 2016 , LexisNexis #0716-048

Rhodes v. Florida Metal Trading Inc. (In re Hayes Iron & Metal Inc.)

Ruling
Section 541(d) did not trump trustee's rights and powers.
Issue(s)
Were trustee's powers superior to any resulting trust, constructive trust or equitable lien established by creditor?

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Commercial opinion summary, case decided on May 22, 2014 , LexisNexis #0614-091

In re Sanchez-Villalba

Ruling
Plan ordered amended to include one quarter equity interest in property held by debtor.
Procedural posture

This cause came before the court for hearing upon the trustee's objection to confirmation of debtor's plan, based on the assertion that debtor owned 1/4 of certain real properties and therefore the value of 1/4 of the properties should be included in debtor's estate under 11 U.S.C.S. § 541.

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Consumer opinion summary, case decided on February 23, 2012 , LexisNexis #0312-130

In re Herlan

Ruling
Debtor real estate agent ordered to turn over vacation home management contracts to resort.
Procedural posture

Movant principal sought an immediate turnover of vacation home management contracts that were in the possession of a chapter 11 debtor under 11 U.S.C.S. § 541(d) on the grounds that the principal was the equitable owner of those contracts. The court granted the oral motion of the principal to add a realty company as a moving party in its motion for turnover.

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Consumer opinion summary, case decided on January 06, 2010 , LexisNexis #0210-014