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§ 547(b)(5)

Sanger, In re--Sanger v. JMG Partners 2021, LP

Ruling
Debtors could not avoid sale as a preferential transfer as the tax sale was held in compliancewith state law. (Bankr. M.D. Pa.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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Consumer opinion summary, case decided on August 01, 2023 , LexisNexis #0923-091

Code Ann. § 66-12-102. Clinton Nurseries, Inc., In re--Clinton Nurseries, Inc. v. Pirtle Nursery, Inc.

Ruling
Debtor's agreement to make monthly payments based on the number of trees planted on the creditor's farm was a lease rather than a services contract for purposes of preference proceeding. (Bankr. D. Conn.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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Commercial opinion summary, case decided on March 17, 2023 , LexisNexis #0523-038

Code Ann. § 66-12-102. Clinton Nurseries, Inc., In re--Clinton Nurseries, Inc. v. Pirtle Nursery, Inc.

Ruling
Debtor's agreement to make monthly payments based on the number of trees planted on the creditor's farm was a lease rather than a services contract for purposes of preference proceeding. (Bankr. D. Conn.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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Commercial opinion summary, case decided on March 17, 2023 , LexisNexis #0523-038

Apex Rd. Commercial, LLC, In re--Meininger v. Phillips

Ruling
Trustee did not establish that defendants obtained any avoidable, "cognizable" benefit as aresult of debtor's release of the litigation claims. (Bankr. M.D. Fla.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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Commercial opinion summary, case decided on June 03, 2022 , LexisNexis #0822-016

Reagor-Dykes Motors, LP, In re--Faulkner v. Ford Motor Credit Co., LLC

Ruling
Trustee could not rely on the Ponzi-Scheme Presumption to relieve himself of the burden toprove fraudulent intent as debtor did not operate as a Ponzi scheme but accessed capitalthrough traditional financing that created debtor-creditor relationships. (Bankr. N.D. Tex.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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:
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on June 03, 2022 , LexisNexis #0722-088

NewPage Corp., In re--PIRINATE Consulting Grp., LLC v. ERCO Worldwide

Ruling
Litigation trustee was entitled to avoid a debtor's pre-petition transfer to defendant where contract had expired before the effective date and could not have been assumed by the debtor. (Bankr. D. Del.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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Commercial opinion summary, case decided on April 03, 2018 , LexisNexis #0518-047

Tenderloin Health, FKA, In re--Schoenmann v. Bank of the West

Ruling
Courts may account for hypothetical preference actions within a hypothetical chapter 7 liquidation if factually warranted, supported by appropriate evidence, and if the action would not contravene an independent statutory provision. (9th Cir.)
Issue(s)
Preferences; Avoidable Transfers; Receipt by Creditor.

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:
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on March 07, 2017 , LexisNexis #0417-050

Garner v. Knoll Inc. (In re Tusa-Expo Holdings Inc.)

Ruling
Avoidance properly denied where creditor made transfer from proceeds of own collateral.
Issue(s)
Did the bankruptcy court err in holding that transfers from proceeds of accounts receivable in which creditor held a security interest were not preferential?

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on January 28, 2016 , LexisNexis #0216-125

Sparkman v. American Residential Servs. LLC (In re Anderson Homes Inc.)

Ruling
Payments to contractor during preference period could be avoided regardless of hypothetical lien rights had payment not been made.
Procedural posture

Defendant filed a motion for summary judgment in plaintiff chapter 7 trustee's action, which sought to recover pursuant to 11 U.S.C.S. § 547 a preferential transfer made by the debtor to defendant. The trustee filed a cross-motion for partial summary judgment.

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Commercial opinion summary, case decided on May 25, 2012 , LexisNexis #0612-095

Barber v. Central Bank Illinois (In re Trappers Creek LLC)

Ruling
Transfer avoided as preferential where creditor was not fully secured and could not overcome presumption that debtor was insolvent at time it was made.
Procedural posture

Chapter 7 trustee filed a complaint against defendant creditor seeking to avoid a payment to the creditor by the debtor as a preference pursuant to 11 U.S.C.S. § 547. By way of defense, the creditor alleged alternatively that it was a secured creditor, that the payment was made in the ordinary course of business, and that it was outside the 90-day preference period. The trustee moved for summary judgment.

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Commercial opinion summary, case decided on March 05, 2010 , LexisNexis #0510-097