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§ 549

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

Ruling
Postpetition payments to creditor pursuant to prepetition assignment were not avoidable.
Issue(s)
Were postpetition payments under prepetition assignment agreement avoidable as unauthorized postpetition transfers.

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Commercial opinion summary, case decided on January 15, 2014 , LexisNexis #0214-025

Ellis v. IPC (USA), Inc. (In re Pettit Oil Co.)

Ruling
Transfers that did not involve estate property were not avoidable. (Bankr. W.D. Wash.)
Issue(s)
Whether consigned goods delivered to a debtor postpetition become property of the debtor's estate.

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Commercial opinion summary, case decided on December 19, 2013 , LexisNexis #0816-106

Hopkins v. Frazier (In re Tews)

Ruling
Transfer of trailer paid for prepetition was avoidable where certificate of title issued postpetition.
Issue(s)
Was transfer of trailer avoidable where payment was made prepetition but certificate of title not issued until after petition date?

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Consumer opinion summary, case decided on November 25, 2013 , LexisNexis #1213-091

Rainsdon v. Davisco Foods Intl Inc. (In re Azevedo)

Ruling
Trustee could not recover amounts cheese producer deducted as interest owed on advances for milk deliveries between petition date and date of conversion to chapter 7.
Issue(s)
Whether a chapter 7 trustee was entitled under 11 U.S.C.S. §§ 549 and 550 to recover amounts a cheese producer deducted as interest it was owed on advance payments it made to a debtor for milk the debtor delivered between the date he declared Chapter 12 bankruptcy and the date his case was converted to one under chapter 7 of the Bankruptcy Code.

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Consumer opinion summary, case decided on August 19, 2013 , LexisNexis #0913-055

Krohn v. Burton (In re Swift)

Ruling
Trustee could seek turnover of apartments in which estate had 50 percent despite passage of 18 years prior to filing motion.
Issue(s)
Could trustee seek turnover of debtor's 50 percent interest in apartments after passage of 18 years after default judgment denying discharge.

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Consumer opinion summary, case decided on August 05, 2013 , LexisNexis #0913-024

In re Jirsa

Ruling
Lease with option to purchase avoided as purchase price was less than equivalent value of property.
Procedural posture

A hearing was held on confirmation of the debtors' third amended chapter 13 plan and on their amended motion to reject an executory contract, or in the alternative, to determine that the executory contract was terminated.

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Consumer opinion summary, case decided on May 20, 2013 , LexisNexis #0613-061

Abbott v. Arch Wood Protection Inc. (In re Wood Treaters LLC)

Ruling
Postpetition transfers that did not injure estate could not be avoided by trustee.
Procedural posture

Plaintiff chapter 7 trustee filed complaints against defendant transferees to avoid and recover postpetition transfers of estate property pursuant to 11 U.S.C.S. §§ 549 and 550 that were made by the debtor for the purchase of goods related to the debtor's lumber business.

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Commercial opinion summary, case decided on April 22, 2013 , LexisNexis #0613-024

Alexander v. Jensen-Carter

Ruling
Order allowing trustee to sell debtor's home free and clear affirmed.
Procedural posture

A debtor ex-wife appealed a decision of the U.S. District Court for the District of Minnesota affirming a bankruptcy court order giving possession of disputed property (a house) to appellee trustees of the individual bankruptcy estates of the ex-wife and debtor ex-husband.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 02, 2013 , LexisNexis #0413-140

Gold v. Nova World Intl LLC (In re Harvey Goldman & Co.)

Ruling
Trustee could avoid prepetition payment for machinery that was installed postpetition.
Procedural posture

Debtor, which was subject of an involuntary chapter 7 petition, was a large customer of defendant creditor, a Michigan limited liability company that sold machinery for the debtor's use in various locations. The trustee sought to avoid transactions whereby the debtor had paid for machinery ordered pre-petition, but installed postpetition. Trustee and the creditor each moved for summary judgment.

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Commercial opinion summary, case decided on April 01, 2013 , LexisNexis #0413-130

Schafer v. Hilliard (In re Royal Tours Inc.)

Ruling
Unauthorized postpetition transfers could be avoided but not postpetition payments made to satisfy debt of non-debtor spouse.
Procedural posture

Bankruptcy trustee brought an adversary proceeding against transferee of funds from a bankruptcy debtor alleging that the transfers were avoidable as preferential transfers under 11 U.S.C.S. § 547, that certain transfers were avoidable as unauthorized postpetition transfers under 11 U.S.C.S. § 549. The trustee moved for summary judgment.

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Commercial opinion summary, case decided on March 01, 2013 , LexisNexis #0413-022