IBT International, Inc. v. Northern (In Re International Administrative Services, Inc.)

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that sole shareholder, officer, and director of financial marketing firm and various entities created by his lawyers were not mere conduits who naively transferred funds in scheme to hide firm’s assets from creditors in lawsuit
• rejecting a reading of Section 550(a) to require successive avoidance and recovery actions because it would encourage creditors to “design increasingly complex transactions, with the knowledge that more transfers decrease the likelihood of a successful avoidance action”
• “[T]he distinction between initial transferee and mediate transferee for avoidance purposes is irrelevant!;] defendants need only be transferees.”
• “In fraudulent transfer actions, there is a distinction between avoiding the transaction and actually recovering the property or the value thereof.”
• “If there is not an affirmative good faith defense, then [section] 550(a) allows recovery from subsequent transferees as well.”
• “In short, once the plaintiff proves that an avoidable transfer exists he can then skip over the initial transferee and recover from those next in line.”

Source: CourtListener parenthetical corpus (CC0).