In the bankruptcy court, trustee for Ponzi scheme debtors avoided transfers made by debtors to their sales agents, as fraudulent transfers under 11 U.S.C. § 548. On appeal, sales agents argued that the bankruptcy court lacked subject matter jurisdiction over the avoidance action because debtors were not "persons" eligible for bankruptcy relief, as defined in 11 U.S.C. § 109. Appellants also argued that debtors could not meet the "good faith" requirement for filing bankruptcy petitions, and had no interest in the transferred funds that could be enforced by the trustee, because all of "debtors' property" had been obtained by fraud. The district court held that debtors qualified as "business trusts," which are within the § 109 definition of "corporations," and rejected appellants' first claim. The district court also rejected appellants' good faith claim, on the ground that it was not raised in the bankruptcy court and was a matter within the bankruptcy court's discretion. Appellants' claim that debtors had no interest in the transferred funds was also rejected, based on the reasoning in 180.pdf. However, the district court determined that the bankruptcy court erred in ruling that appellants had failed to convey "legally cognizable value" for the payments they received, concluding that appellants' services constituted "value" as a matter of law. The case was therefore remanded for factual findings by the bankruptcy court on the issue of whether that value was "reasonably equivalent" to the payments appellants received.