Reasonably Equivalent Value And Services

(:description Reasonably Equivalent Value And Services)
REV_Services Value REV Revservices

Because of the mandate that the consideration received by the debtor for a transaction be of "utility to creditors" (as seen through the eyes of creditors), it is often difficult to determine whether services -- as opposed to the sale of land or goods, etc. -- constitute REV. As the articles below indicate, the courts have struggled mightily with this issue and have often ended up with holdings that simply cannot be reconciled.

JayNote: I suggest that the line of cases resulted from The Golf Channel case and its progeny represent the correct holding, which focuses more upon what the transferee gave up than what the debtor received, since if the transferee gave up REV then the transferee was probably not involved in any collusive activity with the debtor to cheat creditors (which is the underlying fundamental purpose of the fraudulent transfer laws generally). However, this should be no more than a presumption that it rebuttable by the facts of a given case.


  • 2020.07.30 ... Zambri Zaps Harrah’s Casino For $850,449.06.0 In Fraudulent Transfers Ordered Repaid To Bankruptcy Trustee
  • 2016.04.07 … The Golf Channel Gets The Answer It Wants From The Texas Supreme Court
  • 2015.07.27 ... The Fifth Circuit Declares A Mulligan In The Golf Channel Innocent Transferee Case
  • 2015.03.17 ... The Fifth Circuit Slices The Golf Channel Into The Pond
  • 2015.03.14 ... Medici Gambles At The Venetian But It Is The Venetian Who Gets Played