Cases

Extrinsic evidence admissible to determine character of support in settlement agreement

In re Aken (6th Cir. BAP 2005)

Bankruptcy Court properly held:

(i) obligations bore required indicia of support under State law to render them non-dischargeable;

(ii) extrinsic evidence may be admitted to explain or vary terms of a marital settlement agreement.

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Unquantifiable benefit not adequate basis for turnover

In re International Management Assoc. (11th Cir. 2005)

An unquantifiable benefit that bears no necessary correspondence to the value of the property transferred or received cannot form the basis for recovery under 550(a)(1) from a person "for whose benefit" the transfer was made.