Gigandet v. Covington (In re Covington)

171 B.R. 294, 1994 Bankr. LEXIS 1296
CourtUnited States Bankruptcy Court, M.D. Tennessee
DecidedAugust 26, 1994
DocketBankruptcy No. 93-01268-GP3-7; Adv. No. 393-0217A
StatusPublished
Cited by2 cases

This text of 171 B.R. 294 (Gigandet v. Covington (In re Covington)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gigandet v. Covington (In re Covington), 171 B.R. 294, 1994 Bankr. LEXIS 1296 (Tenn. 1994).

Opinion

MEMORANDUM

KEITH M. LUNDIN, Bankruptcy Judge.

The question presented is whether Tennessee fraudulent conveyance law permits the Chapter 7 trustee to avoid this debtor’s pre-bankruptcy purchase of a single premium insurance policy and transfer to family members of a remainder interest in real property. The transfers are avoidable. The following are findings of fact and conclusions of law. Fed.R.Bankr.P. 7052.

I

Between 1982 and 1985 this debtor acquired three pieces of real property: (1) a residence known as the “Harrow Court” property; (2) a triplex, the purchase of which was financed by the sellers, James and Barbara Atkeison; and (3) an apartment building, also financed by the seller, James W. Pickle.

On June 2, 1989, the Harrow Court residence was destroyed by fire. In December 1989, the purchase money loan for the apartment building was in default and Pickle began foreclosure. This foreclosure was delayed by the filing of a Chapter 13 bankruptcy by this debtor’s (former) husband. That Chapter 13 case was dismissed. In June 1990, Pickle completed foreclosure. In September 1990, Pickle sued the debtor for the deficiency and damages.

In March of 1991, the debtor received $53,-500 from State Farm Insurance to settle her claim for the Harrow Court fire. After payment of expenses, the debtor had $40,000 in cash.

The debtor consulted her accountant concerning this money. The accountant referred her to a Nashville attorney who is a member of the panel of bankruptcy trustees for this district and who specializes in bankruptcy law. On July 1, 1991, after consultation with bankruptcy counsel, the debtor purchased a single premium life insurance policy for $40,000.

On August 2, 1991, the Atkeisons sued the debtor to collect the balance of the purchase price for the triplex.

On September 26, 1991, after additional consultation with her accountant and bankruptcy counsel, the debtor conveyed the Harrow Court lot to her children, retaining a life estate. The children paid the debtor $3,000. The market value of the lot at the time of transfer was between $12,000 and $20,000.

The Harrow Court property and fire insurance proceeds were the debtor’s only significant assets.

On November 12, 1991, Pickle obtained a judgment against the debtor for $110,365.13. Pickle began garnishing the debtor’s wages. On December 6,1991, the Atkeisons obtained a judgment against the debtor for $11,911.87.

Pickle filed suit in the Chancery Court for Davidson County, Tennessee on June 16, 1992 to avoid the transfer of the Harrow Court property as a fraudulent conveyance. On February 17,1993, the debtor filed Chapter 7. The debtor claimed the cash value of the life insurance policy exempt pursuant to [296]*296Tenn.Code Ann. § 56-7-203.1 The trustee removed Pickle’s fraudulent conveyance action to this court and amended the complaint to allege that the purchase of the single premium life insurance policy was also avoidable pursuant to 11 U.S.C. § 544(b).2

II

Tennessee law voids every conveyance made with the intent or purpose to delay, hinder or defraud creditors. Tenn.Code Ann. §§ 66-3-101, 66-3-308.3 11 U.S.C. § 544(b) permits a bankruptcy trustee to “avoid any transfer of an interest of the debtor in property ... that is voidable under applicable law by a creditor holding an [allowable] unsecured claim.”

The Tennessee Supreme Court has declared that conversion of nonexempt property into exempt property, with the purpose of placing it beyond the reach of creditors is a voidable fraudulent conveyance. Hollins v. Webb, 2 Tenn.Cas. (Shan.) 581 (1877). See also In re Hall, 31 B.R. 42, 45 (Bankr.E.D.Tenn.1983).

In Hollins, the debtor borrowed money using nonexempt personal property as collateral. He used the proceeds to reduce a mortgage on real property to create a homestead exemption. Holding that the debtor’s actions constituted “a fraud upon his creditors, [which] cannot be permitted” the Tennessee Supreme Court explained:

[t]he fraud seems to consist in this: the debtor who has property subject to his creditor’s claim, by his own act places it beyond their reach, and secures to himself all the benefits to be derived from it.

Hollins, 2 Tenn.Cas. (Shan.) at 583.

The Sixth Circuit reached a similar result in Shanks v. Hardin, 101 F.2d 177 (6th Cir.1939). Applying Tennessee law, the court denied a homestead exemption to a debtor who procured deeds to himself from his siblings for the purpose of shielding real property from creditors. Finding Hollins v. Webb to be controlling precedent, the Sixth Circuit held that a debtor who, in contempla[297]*297tion of bankruptcy, converts “property, subject to execution, into a homestead for the express purpose of defeating his creditors” has committed a fraud. Shanks, 101 F.2d at 178. See also In re Hall, 31 B.R. 42, 45 (Bankr.E.D.Tenn.1983) (objection to homestead exemption sustained where “the debt- or, ... while insolvent and in contemplation of bankruptcy, established a homestead exemption in property, which was then subject to execution, for the express purpose of defeating the rights of creditors.”).

The Tennessee courts recognize that fraudulent conveyance eases are fact intensive. See Macon Bank & Trust Co. v. Holland, 715 S.W.2d 347, 349 (Tenn.Ct.App.1986) (“Whether a transfer is fraudulent is determined by the facts and circumstances of each ease.”). The Tennessee appellate courts have identified many “badges of fraud” to guide the trial courts in divining a debtor’s intent for fraudulent conveyance purposes:

1. The transferor is in precarious financial condition.
2. The transferor knew there was or soon would be a large money judgment rendered against the transferor.
3. Inadequate consideration for the transfer.
4. Secrecy or haste in carrying out the transfer.
5. A family or friendship relationship between the transferor and the transferee^).
6. The transfer included all or substantially all of the transferor’s nonexempt property.
7. Retention by the transferor of a life estate or other interest in the property transferred.
8. Failure of the transferor to produce available evidence explaining or rebutting a suspicious transaction.
9. Lack of innocent purpose or use for the transfer.

See Weaver v. Nelms,

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Bluebook (online)
171 B.R. 294, 1994 Bankr. LEXIS 1296, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gigandet-v-covington-in-re-covington-tnmb-1994.