Egan v. Oliver (In Re Oliver)

38 B.R. 407, 1984 Bankr. LEXIS 6165
CourtUnited States Bankruptcy Court, D. Massachusetts
DecidedMarch 5, 1984
Docket17-41441
StatusPublished
Cited by5 cases

This text of 38 B.R. 407 (Egan v. Oliver (In Re Oliver)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Egan v. Oliver (In Re Oliver), 38 B.R. 407, 1984 Bankr. LEXIS 6165 (Mass. 1984).

Opinion

MEMORANDUM AND ORDER ON COMPLAINT TO AVOID A FRAUDULENT TRANSFER

PAUL W. GLENNON, Bankruptcy Judge.

The complaint filed by the Chapter 7 Trustee, John J. Egan (“Trustee”), sought to avoid an alleged fraudulent transfer of real estate by the debtor and his wife. The Court has under advisement the motion of the debtor, David G. Oliver (“debtor”), for summary judgment and the Trustee’s cross-motion for summary judgment. Neither party filed supporting affidavits.

DISCUSSION

The debtor and his wife owned property as tenants by the entirety pursuant to common law principles of Massachusetts. Under the common law, the husband and wife each possessed an indefeasible survivorship right in the tenancy. However, during his lifetime, the husband’s rights were superior to those of his wife. D’Ercole v. D'Ercole, 407 F.Supp. 1377 (D.Mass.1976). During his lifetime, the husband had the right to the rents and profits from, and the use, possession and control of, the property. See Friedman v. Harold, 638 F.2d 262 (1st Cir.1981) and Voigt v. Voigt, 252 Mass. 582, 147 N.E. 887 (1925). The husband could alienate his interest in the property, something that his wife could not do. Phelps v. Simons, 159 Mass. 415, 34 N.E. 657 (1893). Furthermore, the husband’s creditors could attach the jointly owned property and have it sold on execution (subject to the wife’s survivor-ship interest). Raptes v. Pappas, 259 Mass. 37, 155 N.E. 787 (1927). On the other hand, the wife’s sole interest was that of survivorship which, because she could not sell, could not be reached by her creditors. Pineo v. White, 320 Mass. 487, 70 N.E.2d 294 (1946) and Licker v. Gluskin, 265 Mass. 403, 164 N.E. 613 (1929). The husband’s creditors could reach his interest in property held as a tenant by the entirety. Likewise, he could sell his interest, subject always, however, to the wife’s right of survivorship. 1

On November 19, 1980, the debtor and his wife conveyed their property owned as tenants by the entirety, under common law principles, to a straw who reconveyed the property back to the debtor and his wife in order that their ownership would be governed by a revised Massachusetts statute, which substantially changed the rights of *409 tenants by the entirety in the Commonwealth.

Under the revised statute, Mass.Gen. Laws ch. 209 § l, 2 effective February 11, 1980, where property is held as tenants by the entirety, both the husband and wife are entitled equally to the rents and profits from, and the use, control and possession of, the property in question. Creditors of a debtor spouse may not reach the property interest of the debtor spouse if the property is the principal residence of the nondebt- or spouse. However, the property is available to satisfy debts incurred by either spouse or a member of their family on account of “necessaries”.

On February 13, 1981, the debtor filed his Chapter 7 petition. 11 U.S.C. § 522(b)(2)(B) provides that a debtor may exempt his interest in property owned as a tenant by the entirety to the extent it is exempt from process under applicable non-bankruptcy law. 3 Here, the debtor claimed his interest in property held as a tenant by the entirety exempt, relying on § 522(b)(2)(B).

The combined result of the November 1980 conveyances and the February 13, 1981 filing of the above-captioned Chapter 7 petition, was to place the property held by the debtor as a tenant by the entirety, taking advantage of his state exemptions, beyond the reach of the Chapter 7 Trustee and thus unavailable to satisfy the claims of his creditors.

While the Court recognizes that under § 522 it is perfectly proper and indeed may be good planning, for a debtor to convert non-exempt assets into those which are exempt, even on the eve of bankruptcy, 4 the Court also recognizes that under 11 U.S.C. § 548(a) the same transfer 5 may be avoided if: (1) the transfer occurred on or within one year of the filing of the petition, the debtor received less than a reasonably equivalent value in exchange for the transfer and the debtor was insolvent at the time of the transfer or was rendered insolvent thereby; or (2) the transfer made within the time period set forth above was made with the actual intent to hinder, delay or defraud creditors. 6 “The rationale for *410 avoiding prepetition transfers under Code § 548 ... is to preserve assets of the estate”. In re Jamison, 21 B.R. 380, 381-82 (Bkrtcy.D.Conn.1982).

The Trustee seeks to avoid the transfer relying on both § 548(a)(1) and (2). In paragraph 5 of the complaint, the Trustee alleges that transfer was made within one year of the filing of the Chapter 7 petition, with the intent to hinder, delay and defraud creditors, in exchange for a less than reasonably equivalent value and at which time the debtor was insolvent or became insolvent as a result of the transfer. The debt- or answered paragraph 5 as follows: “The [defendants admit that they conveyed their interest in said real estate to themselves, in order to create a new tenancy by entirety, but deny that the transfer was made with the intent to hinder, delay, and defraud creditors, and that the [d]ebtor received less than a reasonably equivalent value in exchange. The [defendants deny that the transfer was fraudlent, within the meaning of 11 U.S.C. [§] 548.” In substance, the debtor argues that summary judgment in his favor is appropriate because the only effect of the transfers was to enable the debtor to avail himself of a state exemption when he filed his Chapter 7 petition. The trustee’s cross-motion requests the Court to deny the debtor’s motion and states there is no question as to any material facts, therefore he is entitled to judgment as a matter of law.

§ 548(a)(1) requires a finding of actual fraudulent intent, a purely factual question. 4 Collier on Bankruptcy, 11 548.02 (15th ed. 1982). From the uncontroverted facts which were presented, I am unable to determine whether the debtor actually intended to defraud his creditors. I have already stated that an exchange of nonexempt property for exempt property is not fraudulent per se. See supra, note 3. Likewise, a transfer of property to a family member, without more, is not necessarily fraudulent. See, e.g., Chichester v. Golden, 204 F.Supp. 634 (S.D.Cal.1962), aff'd in part, modified in part, and rev’d in part, 321 F.2d 250 (9th Cir.1963) and

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Bluebook (online)
38 B.R. 407, 1984 Bankr. LEXIS 6165, Counsel Stack Legal Research, https://law.counselstack.com/opinion/egan-v-oliver-in-re-oliver-mab-1984.