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    Low-income housing tax credits must be included in valuing section 506(a) collateral
    2012-10-15

    In re Creekside Senior Apartments, LP, 2012 Fed App. 0008P (6th Cir. B.A.P. June 29, 2012)

    CASE SNAPSHOT

    In a case of first impression, the Sixth Circuit BAP held that, for purposes of valuing collateral under section 506(a) of the Bankruptcy Code, the availability of Low-Income Housing Tax Credits must be considered in valuing a creditor’s secured claim.

    FACTUAL BACKGROUND

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Real Estate, Tax, Reed Smith LLP, Debtor, Collateral (finance), Tax credit, Limited partnership, Sixth Circuit
    Authors:
    Ann E. Pille
    Location:
    USA
    Firm:
    Reed Smith LLP
    Third Circuit clarifies burden of proof analysis under section 506(a) valuation, and allows lien stripping in chapter 11
    2012-10-15

    In re Heritage Highgate, 679 F.3d 132 (3d Cir. 2012)

    CASE SNAPSHOT

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Reed Smith LLP, Debtor, Unsecured debt, Collateral (finance), Legal burden of proof, Fair market value, Secured creditor, Third Circuit
    Authors:
    Christopher O. Rivas
    Location:
    USA
    Firm:
    Reed Smith LLP
    Reasonableness of pre-petition default rate under section 506(a) not subject to equitable analysis
    2012-10-15

    In re 400 Walnut Associates, L.P., 2012 BL 140988 (E.D. Pa. June 7, 2012)

    CASE SNAPSHOT

    The creditor appealed the denial of its claim for pre-petition interest at the contractual default rate. The district court reversed and remanded the case, holding that the bankruptcy court had incorrectly applied an "equitable analysis" in making its decision.

    FACTUAL BACKGROUND

    Filed under:
    USA, Pennsylvania, Insolvency & Restructuring, Litigation, Reed Smith LLP, Debtor, Interest, Default (law), Default (finance), Title 11 of the US Code, United States bankruptcy court
    Authors:
    Joseph D. Filloy
    Location:
    USA
    Firm:
    Reed Smith LLP
    Purchased claims are subject to preference disallowance under section 502(d)
    2012-10-15

    In re KB Toys, Inc., 470 B.R. 331 (Bankr. D. Del. 2012)

    CASE SNAPSHOT

    Filed under:
    USA, Delaware, Insolvency & Restructuring, Litigation, Reed Smith LLP, Bankruptcy, Debtor, Title 11 of the US Code
    Authors:
    Elizabeth A. McGovern
    Location:
    USA
    Firm:
    Reed Smith LLP
    Letter of credit payment made independent of bond indenture is not a ‘settlement payment’ protected by section 546(e)
    2012-10-15

    In re Qimonda Richmond, LLC, 467 B.R. 318 (Bankr. D. Del. 2012)

    CASE SNAPSHOT

    Filed under:
    USA, Delaware, Insolvency & Restructuring, Litigation, Reed Smith LLP, Bond (finance), Letter of credit, Debtor, Security (finance), Citibank
    Authors:
    Christopher O. Rivas
    Location:
    USA
    Firm:
    Reed Smith LLP
    ‘Intent’ inferred, summary judgment granted in debt recharacterization case
    2012-10-15

    In re Shubh Hotels Pittsburgh, Inc., Bankr. No. 10-26337JAD (Bankr. W.D. Pa. July 24, 2012)

    CASE SNAPSHOT

    Filed under:
    USA, Pennsylvania, Insolvency & Restructuring, Litigation, Reed Smith LLP, Debtor, Interest, Debt, Balance sheet
    Authors:
    Joseph D. Filloy
    Location:
    USA
    Firm:
    Reed Smith LLP
    Bankruptcy court refuses to pierce the veil of Tennessee LLC
    2012-10-16

    The U.S. Bankruptcy Court for the Eastern District of Tennessee ruled in August that an LLC’s creditor could not pierce the LLC’s veil to assert its claim against the LLC’s sole member. In a twist, the LLC’s member, not the LLC, was the debtor in bankruptcy. In re Steffner, No. 11-51315, 2012 WL 3563978 (Bankr. E.D. Tenn., Aug. 17, 2012).

    Filed under:
    USA, Tennessee, Insolvency & Restructuring, Litigation, Stoel Rives LLP, Bankruptcy, Debtor, Limited liability company, Unsecured creditor, United States bankruptcy court
    Location:
    USA
    Firm:
    Stoel Rives LLP
    Secured blanket lien on inventory trumps reclamation rights
    2012-10-15

    In re Furrs Supermarkets, Inc., No. 11-01-10779 SA (Bankr. D.N.M. Aug. 15, 2012)

    CASE SNAPSHOT

    Filed under:
    USA, New Mexico, Insolvency & Restructuring, Litigation, Reed Smith LLP, Debtor, Unsecured debt, Secured creditor, Unsecured creditor
    Authors:
    Jared S. Roach
    Location:
    USA
    Firm:
    Reed Smith LLP
    Bankruptcy court denies debtor’s challenges to prepayment premium and application of state interest rate
    2012-10-15

    A New York bankruptcy court recently rejected a debtor’s challenge to a consensual state court judgment (“Judgment”) in favor of mortgagee, General Electric Capital Corporation (“GECC”), that had accelerated a debt and obtained a prepetition foreclosure judgment against debtor, 410 East 92nd Street (the “Hotel”), in the amount of approximately $74 million. In re: Madison 92nd St. Associates LLC, 472 B.R. 189 (Bankr. S.D.N.Y. 2012).

    Filed under:
    USA, New York, Banking, Insolvency & Restructuring, Litigation, Chadbourne & Parke LLP, Bankruptcy, Debtor, Res judicata and issue estoppel, Foreclosure, United States bankruptcy court
    Authors:
    Pooja Asnani
    Location:
    USA
    Firm:
    Chadbourne & Parke LLP
    “Strong arm” powers Round 4: manufactured home liens
    2012-10-09

    Vanderbilt Mortgage & Finance, Inc. v. Higgason (In re Pierce), 471 B.R. 876 (B.A.P. 6th Cir. 2012) –

    Filed under:
    USA, Banking, Insolvency & Restructuring, Litigation, Real Estate, Troutman Pepper, Debtor
    Location:
    USA
    Firm:
    Troutman Pepper

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