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§ 548(a)(1)

In re Del Corso

Ruling
Sanctions imposed and attorneys'fees ordered disgorged where counsel advised and assisted debtor in unlawful prepetition fraudulent transfer.
Procedural posture

The United States Trustee ("UST") filed a motion for sanctions, pursuant to Fed. R. Bankr. P. 9011, against the debtor's counsel. The UST filed a motion to disgorge the fees and return the fees paid by the debtor to counsel in a chapter 7 case.

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Consumer opinion summary, case decided on December 27, 2007 , LexisNexis #0208-009

Covey v. Hackett (In re Roadrunner Delivery Inc.)

Ruling
Prepetition claim discharged in shareholder's bankruptcy could not be subject of avoidance proceeding in bankruptcy of the corporation.
Procedural posture

Plaintiff chapter 7 trustee filed an adversary proceeding against defendant, a corporate debtor's sole shareholder, claiming that $6,753.95 in payments the debtor made to the shareholder were fraudulent and should be avoided under 11 U.S.C. § 548(a)(1)(B). The shareholder filed a motion to dismiss the trustee's complaint.

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Commercial opinion summary, case decided on December 19, 2007 , LexisNexis #0108-076

Montoya v. Wilson (In re Wilson)

Ruling
Contribution to Roth IRA for which debtors were not eligible was not fraudulent transfer.
Procedural posture

Plaintiff chapter 7 trustee filed an adversary proceeding against defendants, debtors, seeking to avoid as fraudulent under 11 U.S.C. § 548 contributions that the debtors made to their individual retirement accounts ("IRA"). The debtors moved to dismiss. The motion implicated Fed. R. Bankr. P. 7052, which incorporated Fed. R. Civ. P. 52(c).

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Consumer opinion summary, case decided on November 30, 2007 , LexisNexis #0108-100

McGranahan v. Dillard (In re Dillard)

Ruling
Return of one-half interest in property to former spouse after temporary transfer to debtor for refinancing pursuant to divorce decree was not avoidable.
Procedural posture

Plaintiff chapter 7 trustee sought to avoid the transfer of a one-half joint tenancy interest in real property by the debtor to defendant transferee, the debtor's former spouse, pursuant to Cal. Civ. Code § 3439.05, 11 U.S.C. § 548(a)(1)(B), 11 U.S.C. § 547.

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Consumer opinion summary, case decided on October 30, 2007 , LexisNexis #1207-049

Fransen v. Nicassio Corp. (In re Metro Sewer Servs.)

Ruling
De facto merger occurred where corporation signed letter of intent to acquire debtor so that transfers to corporation were avoidable.
Procedural posture

Plaintiff chapter 7 trustee moved for partial summary judgment on certain of its claims against defendants, a corporation and its principals, seeking to recover transfers made to the corporation as fraudulent under 11 U.S.C. § 548(a)(1)(A) and (B), seeking to hold the principals personally liable for the improper transfers, and alleging that the debtor incurred damages as a result of a de facto merger or a joint venture with the corporation.

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opinion summary, case decided on August 10, 2007 , LexisNexis #0907-100

Reaves v. Comerica Bank-California (In re GTI Capital Holdings)

Ruling
Collateralization of antecedent debt conferred new reasonably equivalent value upon debtor for transfer of interest in property.
Procedural posture

Defendant, a secured creditor of chapter 7 debtor, filed a motion for summary judgment in an action brought by plaintiff chapter 7 trustee, alleging that the creditor's late filing of UCC-1 Financing Statements constituted a preference or a fraudulent conveyance that should be avoided and recovered for the benefit of the estate pursuant to 11 U.S.C. §§ 544(b) and 548. The trustee filed a cross motion for summary judgment.

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opinion summary, case decided on August 02, 2007 , LexisNexis #0907-101

Sullivan v. Schultz (In re Schultz)

Ruling
Transfer of disabled debtor's inheritance into special needs trust was not avoidable.
Procedural posture

Plaintiff chapter 7 trustee brought a complaint seeking to avoid the transfer of debtor's inheritance from her grandmother into a special needs trust as a fraudulent transfer pursuant to 11 U.S.C. § 548, to recover the transfer from the special needs trustee pursuant to 11 U.S.C. § 550(a). The issue was whether debtor received reasonable equivalent value, for purposes of 11 U.S.C. § 548(a)(1)(B).

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opinion summary, case decided on May 14, 2007 , LexisNexis #0607-065

Applewhite v. Akin (In re Akin)

Ruling
Debtor's transfer of CD proceeds into childrens'bank accounts within one month prior to filing was avoidable.
Procedural posture

Plaintiff trustee filed a motion for partial summary judgment on his adversary complaint to avoid, pursuant to 11 U.S.C. § 548(a)(1), the transfers by defendant debtors of the proceeds from certificates of deposit (CDs) into bank accounts opened in the names of defendant children.

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opinion summary, case decided on March 20, 2007 , LexisNexis #0607-031

Gredd v. Bear Stearns Sec. Corp. (In re Manhattan Inv. Fund Ltd.)

Ruling
Transfers by debtor to brokerage firm with intent to hinder, delay or defraud creditors were avoidable.
Procedural posture

Chapter 11 trustee and defendant brokerage firm filed cross-motions for summary judgment in trustee's action, which sought to avoid margin payments deposited in debtor's account at the firm pursuant to 11 U.S.C. § 548(a)(1)(A).

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opinion summary, case decided on January 09, 2007 , LexisNexis #0207-061

Fisher v. Moon (In re Fisher)

Ruling
Duly noticed and conducted foreclosure sale for less than reasonable value was not a fraudulent transfer.
Procedural posture

Defendant county treasurer foreclosed on debtor's property for non- payment of property taxes. The total consideration received was the outstanding tax obligation of $1,843.75. Debtor and the chapter 13 trustee filed an avoidance action under 11 U.S.C. § 548(a)(1)(B), claiming the value of the property was approximately $68,000, and thus the transfer by the treasurer constituted a fraudulent conveyance. The parties moved for summary judgment.

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opinion summary, case decided on October 04, 2006 , LexisNexis #1106-096