William D. Matthews, Arnall Golden Gregory LLP, Atlanta, GA, for Plaintiff., Archana Ravindranath, Christopher M. Whitcomb, US Dept. of Justice-Tax Division, Washington, DC, Brooke E. Heinz, The Office of the Attorney General, Paul M. Alexander, William A. DuPre, IV, Megan Taylor, Miller & Martin, PLLC, Robert J. Proctor, Proctor, Felton & Chambers, Theodore N. Stapleton, Theodore N. Stapleton, P.C., Matthew R. Brooks, Troutman Sanders LLP, Todd E. Hennings, Macey, Wilensky & Hennings, LLP, George Koenig, Koenig Law Group, PC, Ron C. Bingham, II, Adams and Reese, LLP, Atlanta, GA, Geoffrey H. Bracken, Charles M. Seely, Gardere Wynne Sewell LLP, Houston, TX, for Defendants., U.S. Department of Justice, Washington, D.C., pro se., Automobile Acceptance Corp., McDonough, GA, pro se., Danco Financial Inc., Smyrna, GA, pro se., State Bank, Atlanta, GA, pro se., Chatham Hill Association, Inc., Atlanta, GA, pro se., 1) Synovus Bank's Renewed Motion for Judgment on the Pleadings with attached Memorandum in Support , filed by Synovus Bank ("Synovus") on December 12, 2017 (Docket No. 84);, 2) Plaintiff's Motion for Partial Summary Judgment , filed by Neil C. Gordon, the duly appointed Chapter 7 Trustee in the underlying Chapter 7 case and the Plaintiff herein (the "Trustee") on December 15, 2017 (Docket No. 85) along with Plaintiff's Statement of Material Facts As To Which There Is No Genuine Issue To Be Tried (Docket No. 86) and the Memorandum of Law in Support of Plaintiff's Motion for Partial Summary Judgment (Docket No. 87);, 3) The United States' Motion for Partial Summary Judgment, Statement of Material Facts As To Which There Is No Genuine Issue To Be Tried, and Memorandum in Support of Motion for Partial Summary Judgment , filed by the United States of America, by and through its agency the Internal Revenue Service (the "IRS") concurrently on December 15, 2017 (Docket No. 88);, 4) Defendant J. Richard Stephens' Motion for Summary Judgment, Brief in Support of Motion for Summary Judgment , and Documentary Appendix To Motion for Summary Judgment , filed by J. Richard Stephens ("Stephens") on December 15, 2017 (Docket No. 89) along with Defendant J. Richard Stephens' Statement of Material Facts Not In Genuine Dispute In Support of Motion for Summary Judgment (Docket No. 90);, 8) Memorandum of Synovus Bank Opposing Motions for Summary Judgment by the Trustee, by J. Richard Stephens, and by The Internal Revenue Service , filed by Synovus on January 12, 2018 (Docket No. 97);, 9) Response of Synovus Bank to Defendant J. Richard Stephens' Statement of Material Facts Not In Genuine Dispute In Support of Motion for Summary Judgment , filed by Synovus on January 12, 2018 (Docket No. 98);, 12) Memorandum of Law in Response to the United States' Motion for Partial Summary Judgment, to J. Richard Stephens' Motion for Summary Judgment, and to Synovus Bank's Motion for Judgment on the Pleadings , filed by the Trustee on January 12, 2018 (Docket No. 101);, 13) Synovus Bank's Reply In Support of Renewed Motion for Judgment on the Pleadings , filed by Synovus on January 26, 2018 (Docket No. 102);, 15) Reply Brief in Support of Trustee's Motion for Partial Summary Judgment , filed by the Plaintiff on January 26, 2018 (Docket No. 104)., The Trustee subsequently moved to sell the Property to third party buyers. See generally Main Case Docket Nos. 25, 26, 32, 34, and 43. Sandra Johnson consented to the sale of her interest in the Property. See Main Case Docket Nos. 36, 38, and 45. No party objected to the sale. Main Case Docket, passim . The Court entered an Order authorizing the sale. Main Case Docket No. 46. Subsequently, the Trustee sold the Property. Main Case Docket No. 51. Because there was no dispute that at all times Sandra Johnson owned at least a one-half (1/2) interest in the Property, the Court directed the Trustee to disburse one-half of the sale proceeds to counsel for Sandra Johnson, less certain costs of sale and taxes. Docket Nos. 41, 50, and 57., With regard to Synovus, Stephens further notes that, due to the Transfer, no subsequently filed judgment or tax lien attached to an interest of the Debtor in the Property. Moreover, under Georgia law, a fraudulent transferor of property acquires no interest in the property recovered by virtue of the avoidance of its transfer adjudged as fraudulent. Citing the Official Comments to the Uniform Voidable Transactions Act as adopted in Georgia, Stephens contends that the remedy set forth in O.C.G.A. § 18-2-77(a)(1) provides that not only is the property not restored to the debtor, but the avoidance only inures to the benefit of the acting creditor. Stated differently, the U.F.T.A. is not designed to invalidate transfers generally, but to provide a cause of action for a particular petitioning creditor to have a transfer set aside as a form of relief. This remedy is provided whether or not the petitioning creditor holds a judgment against the debtor or even enjoys any lien rights in the subject property. In sum, Stephens contends that Synovus never attained a lien on any interest of the Debtor in the Property, and has no claim to the Net Sale Proceeds since it did not bring a timely claim under the U.F.T.A. within the four (4) year period required under O.C.G.A. § 18-2-79. See also O.C.G.A. § 18-2-74(a)(1) & (2) ; O.C.G.A. § 18-2-75(a)., Summary judgment may be granted pursuant to Federal Rule of Civil Procedure 56, applicable herein through Federal Rule of Bankruptcy Procedure 7056, if "there is no genuine issue as to any material fact and ... the moving party is entitled to a judgment as a matter of law." Fed.R.Civ.P. 56(c). In deciding a motion for summary judgment, the court "is not to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial." Anderson v. Liberty Lobby, Inc. , 477 U.S. 242, 249, 106 S.Ct. 2505, 2511, 91 L.Ed.2d 202, 212 (1986). Further, all reasonable doubts should be resolved in favor of the non-moving party, and "if reasonable minds could differ on any inferences arising from undisputed facts, summary judgment should be denied." Twiss v. Kury , 25 F.3d 1551, 1555 (11th Cir. 1994), citing Mercantile Bank & Trust Co. v. Fidelity & Deposit Co. , 750 F.2d 838, 841 (11th Cir. 1985). Presumptions or disputed inferences drawn from a limited factual record cannot support entry of summary judgment, and the court cannot choose between competing inferences. See Allen v. Tyson Foods, Inc. , 121 F.3d 642, 646 (11th Cir. 1997) ; Raney v. Vinson Guard Serv., Inc. , 120 F.3d 1192, 1196 (11th Cir. 1997)., Although various motions have been filed and submitted for decision with supporting memoranda and exhibits, the posture of this proceeding is essentially cross-motions for summary judgment. Given the state of the record, and because material outside the pleadings has been offered, Synovus' Renewed Motion for Judgment on the Pleadings may be considered under the same standard. See Fed.R.Bankr.P. 7012(b) ; Fed.R.Civ.P. 12(d) ; see also Property Mgmt. & Inv., Inc. v. Lewis , 752 F.2d 599, 604 (11th Cir. 1985). In addition, each party has consented to entry by this Court of a final order or judgment on the issues presented for decision. Based on its review of the record, only questions of law remain for decision., This conclusion does not, however, entirely resolve the matter. There remain the claims by Stephens and the Trustee for recovery of their expenses incurred in certain parts of this enforcement odyssey. First, Stephens contends that he is entitled to a recovery based on the Georgia "common-fund" doctrine, which allows for the payment of attorney's fees when litigation pursued by one party produces benefits in which others may share who were not a party to that proceeding. See e.g. State v. Private Truck Council, Inc. , 258 Ga. 531, 534-35, 371 S.E.2d 378, 381 (1988) ; Ewing v. First Nat'l Bank of Atlanta , 209 Ga. 932, 76 S.E.2d 791 (1953) ; see also The Boeing Co. v. Van Gemert , 444 U.S. 472, 478, 100 S.Ct. 745, 62 L.Ed.2d 676 (1980). This doctrine of taxing certain costs in equitable actions against beneficiaries to a successful lawsuit who did not otherwise contribute to its cost, is a well-recognized exception to the rule that litigants bear their own attorney's fees. It protects a party who labors to create the common fund and prevents unjust enrichment., Finally, the Trustee claims entitlement to a surcharge against the Net Sale Proceeds as compensation for the "reasonable, necessary costs and expenses of preserving, or disposing, of [the Property] to the extent of any benefit to the holder of such claim," which in this case is Synovus. See 11 U.S.C. § 506(c). The parties herein all agreed to the sale of the Property conducted by the Trustee that generated the Net Sale Proceeds, and it is undisputed that his efforts regarding same benefitted Synovus on its secured claim. These efforts are detailed in the Report of Sale filed by the Trustee on June 27, 2016. See Main Case Docket No. 51; see also Order entered on June 16, 2016 (Main Case Docket No. 46)(granting Trustee's Motion For Authority To (A) Sell Real Property of the Estate Free and Clear of Liens, Claims, Interests, and Encumbrances and (B) Disburse Proceeds at Closing (Main Case Docket No. 32) ); and Order Approving Settlement Agreement entered on June 16, 2016 (Main Case Docket No. 45)(granting Motion for Approval of Agreement Between Trustee and Sandra Thome Johnson (Main Case Docket No. 36) )., The Court agrees that the Trustee may recover an appropriate portion of such fees and costs as an administrative expense, recoverable from the Net Sale Proceeds pursuant to 11 U.S.C. § 506(c). The Court also agrees that the Trustee may recover the fees and expenses incurred in filing the Complaint. The distribution of the Net Sale Proceeds would have ultimately required judicial decision or consensual agreement, and the Trustee's efforts in initiating this process conferred a benefit on the secured claimants to that extent. The Trustee is not, however, entitled to all of his fees and expenses incurred in conducting this litigation. A substantial discount may be required for fees and expenses related to his argument for one distribution scheme over another, since the Trustee could have simply interpled the Net Sale Proceeds rather than taking a position on their distribution., ORDERED that Synovus Bank's Renewed Motion for Judgment on the Pleadings be, and the same hereby is, granted in part and denied in part as provided herein; and, it is further, ORDERED that the Plaintiff's Motion for Partial Summary Judgment be, and the same hereby is, denied except as provided herein; and, it is further, ORDERED that the United States' Motion for Partial Summary Judgment be, and the same hereby is, granted to the extent that its interest in the Net Sale Proceeds is not avoided as a preference; and, it is further, ORDERED that Defendant J. Richard Stephens' Motion for Summary Judgment be, and the same hereby is, granted to the extent provided herein and otherwise denied ; it is further, ORDERED (i) that the Trustee may file in this Adversary Proceeding and serve on the parties herein and the United States Trustee within twenty-one (21) days of entry of this Order an application for reasonable attorneys' fees and expenses incurred in connection with the sale of the Property and the filing and prosecution of this Adversary Proceeding. Such application shall show how same were reasonable, necessary, and provided benefit to secured creditors and are otherwise shall be in compliance with the Guidelines of the United States Trustee, and (ii) any party herein may file in this Adversary Proceeding and serve on the Trustee any objections to such application within fourteen (14) days of the filing of such application. It is further, ORDERED that once an amount is approved for the fees and expenses of Stephens and the Trustee, the Net Sale Proceeds shall be distributed by the Trustee as follows: the amounts allowed to the Trustee and Stephens shall be paid first, and the balance of the Net Sale Proceeds shall be paid to Synovus for application to its secured claim., The Clerk is directed to serve a copy of this Order upon counsel for the Plaintiff-Chapter 7 Trustee, counsel for Synovus, counsel for J. Richard Stephens, counsel for the I.R.S., counsel for all other party defendants herein, and the United States Trustee., A Final Declaratory Judgment as to Georgia Department of Revenue was entered regarding Defendant Georgia Department of Revenue on December 18, 2017 (Docket No. 91). Defendants Amegy Bank, N.A, (Docket Nos. 43, 44, and 47) and SunTrust Bank, N.A. (Docket Nos. 21 and 26) were previously dismissed from this action and do not assert any interest in the funds at issue in this matter. The remaining Defendants, Automobile Acceptance Corp., Danco Financial Inc., State Bank, and Chatham Hill Association, Inc., did not answer the Complaint. Further, they did not respond to the Trustee's Motion for Partial Summary Judgment or otherwise dispute the Trustee's revised listing of encumbrances against the subject property as defined herein, which did not include any interest in favor of these entities. See Plaintiff's Statement of Material Facts, ¶ 18 (Docket No. 86); compare Complaint, ¶ 19(iv), (v), and (xiii), and see ¶¶ 20 and 25 (Docket No. 61). State Bank filed a proof of claim (Claim No. 6) on May 25, 2016 secured in the amount of $2,022,834.41 based on a judgment lien dated February 18, 2014., See Exhibit "A," as attached to Documentary Appendix to Motion for Summary Judgment by J. Richard Stephens , filed on December 15, 2017 (Docket No. 89)(the "Documentary Appendix")(citations to Exhibits hereinafter are references to the Documentary Appendix). No party has disputed the authenticity of the document copies contained in the Documentary Appendix., Under Georgia law, a transfer tax is imposed on the conveyance of real property based on the consideration paid for the property conveyed, and is paid prior to the recording of the applicable deed or other instrument. See O.C.G.A. § 48-6-1. The failure to pay such tax is indicative of a lack of consideration and suggests the underlying transfer was a gift. Flatau v. Smith (In re Smith) , 2007 WL 3238717, *2 (Bankr. M.D. Ga. Oct. 30, 2017)., (1) to or for the benefit of a creditor;, (2) for or on account of an antecedent debt owed by the debtor before such transfer was made;