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For several years now the bankruptcy and lending communities have been abuzz over the now concluded "Tousa Saga,"1 a fraudulent conveyance lawsuit that began with a multi-hundred million dollar disgorgement ordered by the Bankruptcy Court for the Southern District of Florida,2 reversed by the District Court for the Southern District of Florida,3 and ultimately reinstated by the Eleventh Circuit.4 The Tousa line of decisions is remarkable and unique due to the amount of money involved, the nature of the transaction at question and the sweeping relief granted by the bankruptcy court. Practitioners, however, should not dismiss the Tousa line of decisions as limited to the transactions and factual circumstances involved.

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