Chapter 11 trustee filed an adversary complaint against a limited partnership, of which debtor was the general partner, seeking to quiet title to a mobile home park and adjacent unimproved property. The partnership responded that, since it held equitable title to the subject real property, trustee's 11 U.S.C. § 544(a)(3) right to stand in the shoes of a bona fide purchaser was limited by 11 U.S.C. § 541(d) to debtor's bare legal title. Therefore, the partnership argued, trustee lacked the power to avoid partnership's equitable interest under § 544. The court disagreed that § 541(d) limits trustee's avoidance powers, since § 541(d) relates only to property made part of the estate by § 541(a)(1) or (2), or to debtor's prepetition property; whereas property recovered pursuant to a trustee's avoidance powers becomes part of the bankruptcy estate through § 541(a)(3) or (4). Thus, a bankruptcy estate consists of both debtor's prepetition property and property that the trustee recovers by avoidance. In any event, the court concluded that, under Utah law, one with legal title could transfer that property to a bona fide purchaser free and clear of an unrecorded equitable interest. Partnership also claimed that trustee could not be a bona fide purchaser under 11 U.S.C. § 544(a)(3), because partnership's actual, open, and unambiguous possession of the property when the petition was filed gave trustee inquiry notice, requiring him to investigate partnership's interest. However, the court found that the facts did not support partnership's claim, since nothing about the operation/possession of the property was in conflict with debtor's record title.

Plaintiffs filed a complaint against chapter 7 debtor under 11 U.S.C. § 727(a)(4)(A), alleging debtor failed to list property and to disclose bank accounts and partnership income in his schedules and statement of affairs. Debtor responded that the assets he failed to list were worthless or unavailable to creditors, and that he had revealed the assets to the trustee, both at the meeting of creditors and thereafter. The court held that deliberate omissions by a debtor may result in a denial of the debtor's discharge, and that debtor's assertions of lack of value were insufficient to relieve him from his duty to disclose all of his property interests in the bankruptcy. Additionally, debtor's alleged disclosures to the trustee were insufficient to satisfy his disclosure duty. Based on debtor's cumulative omissions, and the fact that debtor was an attorney professing knowledge of bankruptcy law, the court found that plaintiffs had established that debtor's failure to fully disclose assets was knowing and fraudulent, and debtor's discharge was denied.

Plaintiff leased tanning equipment to debtors, and the lease was secured by both the equipment and debtors' home. Debtors filed a chapter 13 petition and submitted a plan providing that the equipment would be surrendered to plaintiff, and that any deficiency would become an unsecured claim, the amount of which would be determined at the confirmation hearing. Prior to confirmation, debtors returned the leased equipment to plaintiff. Plaintiff then filed a proof of claim for the full amount owed under the lease, inadvertently listing its claim as unsecured. No reduction for the value of the returned equipment was made. Debtors did not object to the proof of claim, and plaintiff did not attend the confirmation hearing. The order confirming the plan provided that surrender of the equipment fully satisfied plaintiff's claim. Plaintiff filed an action to set aside the confirmation order and to modify the plan to reflect it as a secured creditor. The bankruptcy court granted debtors' motion to dismiss, and plaintiff appealed. The district court affirmed on the ground that plaintiff's lien had been satisfied, but specifically rejected the bankruptcy court's position that an order of confirmation could avoid an otherwise valid lien by operation of law. The court considered the bankruptcy court's ruling to implicitly value the surrendered equipment as equal to the value of plaintiff's claim, and concluded that plaintiff, by its failures to object to the plan, appeal the order confirming the plan, or argue on appeal that the plan did not satisfy the requirements of 11 U.S.C. § 1325(a)(5), was estopped from asserting that surrender of the equipment did not fully satisfy its claim.

The bankruptcy court granted judgment in favor of chapter 11 trustee, concluding that debtors had made several preferential and fraudulent transfers to defendant. The sole issue on appeal was whether defendant's investments in a diamond and gold exchange should be considered value given to debtor clearinghouses, based on identity of interest between the exchange and debtors. The district court affirmed the bankruptcy court's judgment, concluding that there was no evidence that investments in the exchange constituted value and consideration for transfers made by debtor clearinghouses.