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§ 549(a)

Insight Terminal Sols., LLC, In re

Ruling
Debtor was allowed to conduct a Fed. R. Bankr. P. 2004 examination of the city as sought to determine whether the city's transactions with respect to certain property might constitute an avoidable post-petition transaction. (Bankr. W.D. Ky.)
Issue(s)
Postpetition Transactions; Trustee’s Power to Avoid Transfers.

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Commercial opinion summary, case decided on August 26, 2024 , LexisNexis #1124-015

Fresh Acquisitions, LLC, In re--Gonzales v. SZTX Invs., LLC

Ruling
Post-petition transfers of property of the estate to an insider in connection with fees and costsfor a debtor-in-possession financing were avoidable as not authorized by the DIP order.(Bankr. N.D. Tex.)
Issue(s)
Post-petition Transactions; Trustee’s Power to Avoid Transfers.

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Commercial opinion summary, case decided on August 01, 2023 , LexisNexis #0923-065

Mattes, In re--Overcash v. Bank of Dixon Cnty.

Ruling
Bank's post-petition notation of its lien on certificate of title was avoidable as an unauthorizedpost-petition transfer. (Bankr. D. Neb.)
Issue(s)
Post-petition Transactions; Trustee’s Power to Avoid Transfers.

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Consumer opinion summary, case decided on June 08, 2022 , LexisNexis #0822-017

Lemmons, In re

Ruling
Post-petition lien of creditor mortgage company was avoidable as debtor's post-petitionrefinance was done without court authorization. (Bankr. D. Idaho)
Issue(s)
Post-petition Transactions; Trustee’s Power to Avoid Transfers.

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Consumer opinion summary, case decided on August 13, 2019 , LexisNexis #1019-040

BX Acquisitions, Inc., In re--Eisenberg v. Toledo-Lucas Cty. Port Auth.

Ruling
Trustee could not avoid debtor's postpetition payments to defendant on a prepetition debtbecause they were authorized by court as necessary to debtor's organization. (Bankr. N.D. Ohio)
Issue(s)
Postpetition Transactions; Trustee’s Power to Avoid Transfers; Authorization; Unauthorized Transfers

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Commercial opinion summary, case decided on May 04, 2018 , LexisNexis #0618-017

SunTrust Bank v. Matson (In re CHN Constr. LLC)

Ruling
Creditor could not pursue avoidance proceeding based on transfers made by chapter 11 debtor in possession prior to conversion to chapter 7.
Issue(s)
Whether the court could authorize a creditor to commence causes of action under 11 U.S.C.S. §§ 549 and 550(a) against joint payees that engaged in business with debtor while it operated as a debtor in possession (DIP) prior to its conversion to chapter 7.

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Commercial opinion summary, case decided on May 18, 2015 , LexisNexis #0615-059

In re Bill

Ruling
Debtor's mother's postpetition grant of a security interest in debtor's boat could be avoided as unauthorized.
Issue(s)
Was the grant of a security interest in debtor's boat by the debtor's mother an avoidable postpetition transfer?

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Consumer opinion summary, case decided on April 16, 2015 , LexisNexis #0515-058

Sender v. Golden (In re Golden)

Ruling
Postconfirmation transfer of chapter 13 debtor's homestead to former spouse prior to conversion to chapter 7 was not avoidable.
Issue(s)
Whether a chapter 7 trustee could avoid a post-petition, pre-conversion transfer of proceeds from the sale of debtor's homestead to his former wife under 11 U.S.C.S. § 549(a).

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Consumer opinion summary, case decided on March 16, 2015 , LexisNexis #0415-021

Pergament v. Pagano (In re Tolkin)

Ruling
Postpetition preconversion transfer was avoidable as were postconversion transfers paid from prepetition earnings.
Procedural posture

Plaintiff bankruptcy trustee brought an adversary proceeding against defendant creditor seeking to avoid transfers of funds to the creditor pursuant to 11 U.S.C.S. § 549(a) as unauthorized postpetition transfers.

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Consumer opinion summary, case decided on April 05, 2011 , LexisNexis #0511-124

Faulkner v. Wyndham Jade LLC (in re Home Interiors & Gifts Inc.)

Ruling
Check issued prior to petition date for prepetition invoices, which cleared after petition date, could be avoided.
Procedural posture

Plaintiff creditor trust trustee filed an amended complaint against defendant creditor seeking to avoid a transfer and recover the same from the creditor pursuant to 11 U.S.C.S. §§ 549 and 550.

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Commercial opinion summary, case decided on March 24, 2011 , LexisNexis #0411-124