Davis v. Pham (In re Nguyen)

Debtor's prepetition transfer of bare legal title to sister by quit claim deed could not be avoided.
Procedural posture: 
Chapter 7 trustee filed a complaint pursuant to 11 U.S.C.S. § 548 against a debtor's sister and others, to avoid the debtor husband's prepetition transfer to his sister by quit claim deed of an interest in real property. The court directed the trustee to file a brief addressing the question of appropriate remedy and allowed defendants to file a response.
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Consumer case opionion summary, case decided on January 15,2013, LexisNexis #0213-014