New York Western District

On Dismissal in ‘13,’ the Debtor Gets a Refund Regardless of a Property Execution

The Supremacy Clause overrides a property execution when a chapter 13 petition is dismissed before confirmation.

Courts Divided on Broad or Narrow Grounds for Transferring Venue Under Section 1412

Some courts don’t transfer venue under 28 U.S.C. § 1412 if the claims are only ‘related to’ the bankruptcy and don’t arise in the bankruptcy case or arise under the Bankruptcy Code.

Another District Judge Rules that Tax Foreclosures Can Be Fraudulent Transfers

The circuits are split on whether the Supreme Court’s BFP opinion can be extended to bar fraudulent transfer attacks on in rem real estate tax foreclosures.

Courts Split on Stripping Down Partially Commercial Mortgages

Buffalo case begs for circuit court ruling to set up a circuit conflict and cert petition.