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Two Circuits Agree on When Social Security Benefits Accrue

The Third and Seventh Circuits agree on a concept that limits a debtor’s ability to recover accrued Social Security benefits that are set off before bankruptcy.
Court: 

Circuit Split Narrows on the New Value Defense to a Preference

Eleventh Circuit abandons the notion that new value must remain unpaid to offset a preference.
Court: 

Tax Foreclosure in New York Can Be a Fraudulent Transfer, District Judge Says

The Supreme Court’s BFP opinion on mortgage foreclosures held not applicable to tax foreclosures in New York.

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