An interesting bankruptcy law issue that has been litigated in the U.S. Bankruptcy Court for the Eastern District of New York is whether a pre-petition private school tuition payment by a Chapter 7 debtor for a dependent child is avoidable as a constructive fraudulent conveyance under either federal or New York law. Chief Judge Carla Craig and Judge Elizabeth Stong have held that a pre-petition private school tuition payment by a Chapter 7 debtor for a dependent child is not avoidable as a constructive fraudulent conveyance. Geltzer v. Xaverian High School (In re Akanmu), 502 B.R. 124 (Bankr. E.D.N.Y. 2013) (C.J. Craig); Geltzer v. Lawrence Woodmere Academy (In re Michel), 2017 WL 4158831 (Bankr. E.D.N.Y. 2017) (J. Stong).
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