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§ 547(c)(2)(A)

Buehler, In re--Schnittjer v. Buehler

Ruling
Trustee could not recover debtor's lease payment as it satisfied the ordinary course of businessexception. (Bankr. N.D. Iowa)
Issue(s)
Preferences; Exceptions to Avoidance; Payments in Ordinary Course of Business;

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Consumer opinion summary, case decided on March 21, 2022 , LexisNexis #0522-062

HHGREGG, Inc., In re--Official Comm. of Unsecured Creditors v. Curtis Int'l Ltd.

Ruling
Balance of transfers fell within the ordinary course of business exception and were notavoidable. (Bankr. S.D. Ind.)
Issue(s)
Preferences; Exceptions to Avoidance; Payments in Ordinary Course of Business;

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:
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on February 03, 2022 , LexisNexis #0322-091

LMCHH PCP, LLC, In re--LMCHH PCP, LLC v. Crescent Imaging, LLC

Ruling
Payments were preferential transfers where debtor failed to prove the ordinary course defense. (Bankr. E.D. La.)
Issue(s)
Preferences; Exceptions to Avoidance; Payments in Ordinary Course of Business; Made in Ordinary Course of Business.

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Court :
Commercial opinion summary, case decided on July 06, 2020 , LexisNexis #0820-065

Satija v. C-T Plaster Inc. (In re Sterry Indus.)

Ruling
Preference period payments were not subject to avoidance as they were made in the ordinary course of business.
Issue(s)
Was debtor pool installers preference period payment to subcontractor protected from avoidance by the ordinary course of business exception?

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Consumer opinion summary, case decided on June 09, 2016 , LexisNexis #0716-020

Stanziale v. Industrial Specialists Inc. (In re Conex Holdings LLC)

Ruling
Payments made in the ordinary course of business between debtor and creditor were not avoidable.
Issue(s)
Did ordinary course of business defense apply to bar avoidance of allegedly preferential transfers?

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Commercial opinion summary, case decided on December 18, 2014 , LexisNexis #0115-056

Bel Air Indus. of PR v. H Keller Trading Corp. (In re Bel Air Indus. of PR)

Ruling
Payments to creditor were not avoidable preferential transfers as they were made in the ordinary course of business.
Issue(s)
Were preference period transfers avoidable or was the ordinary course of business defense applicable?

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Commercial opinion summary, case decided on November 25, 2014 , LexisNexis #1214-127

Weinman v. New Penn Motor Express Inc. (In re Office Source Inc.)

Ruling
Summary report intended to establish ordinary course of business defense was admissible but only established defense for one of two creditors.
Issue(s)
Did summary reports provide basis for establishing ordinary course of business defense for two creditors in preference proceeding.

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Commercial opinion summary, case decided on December 11, 2013 , LexisNexis #0114-022

Burtch v. Prudential Real Estate & Relocation Servs. (In re AE Liquidation Inc.)

Ruling
Payments pursuant to quicker than usual payment schedule were not made in ordinary course of business and were avoidable.
Procedural posture

Chapter 7 trustee filed a complaint against creditor to avoid and recover preferential transfers under 11 U.S.C.S. § 547(b). The creditor argued that the trustee failed, as a matter of law, to establish a prima facie case. In the alternative, the creditor asserted two defenses under § 547(c)

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Commercial opinion summary, case decided on July 17, 2013 , LexisNexis #0813-021

Goldstein v. Starnet Capital Group LLC

Ruling
Payments made in ordinary course of business were not avoidable.
Procedural posture

The chapter 7 trustee brought an adversary proceeding to set aside the $175,000 in multiple pre-petition transfers as fraudulent transfers pursuant to 11 U.S.C.S. §§ 544, 548 and 550. Alternatively, the trustee sought to avoid the final two of the transfers as preferences under 11 U.S.C.S. §§ 547(b) and 550, as made to the transferee within 90 days of the petition date.

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Commercial opinion summary, case decided on October 24, 2012 , LexisNexis #1112-054

Jacobs v. Gramercy Jewelry Mfg. Corp. (In re M. Fabrikant & Sons Inc.)

Ruling
Preference period payments made much later than debtor's usual practice were not made in ordinary course of business and were voidable.
Procedural posture

Plaintiff, a trustee of a shared assets trust, filed an adversary proceeding against defendant creditor under 11 U.S.C.S. § 547(b) to recover funds paid by the Chapter 11 debtors during the 90-day preference period. The trustee established a prima facie case under § 547(b). At issue was whether the transfers were incurred and made in the ordinary course of business or financial affairs of the debtors and the creditor under § 547(c)(2)(A).

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Commercial opinion summary, case decided on November 04, 2010 , LexisNexis #1210-052