A Tax Foreclosure Ok Under Tyler Can Still Be a Fraudulent Transfer
Quick Take
A tax foreclosure that isn’t an unconstitutional taking can still be a constructively fraudulent transfer depending on when and how the debtor receives the equity above the delinquent taxes.
Courts Must Use Inherent Powers for Sanctions on Pro Se Litigants, Eleventh Circuit Says
Quick Take
In a nonprecedential opinion, the Eleventh Circuit holds that 28 U.S.C. § 1927 may not be used to impose monetary sanctions on pro se litigants.