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Bankruptcy – Preferential Transfers – Avoidance – Defenses – Ordinary Course of Business — Contemporaneous Value (access required)

Sparkman v. American Residential Services, LLC (In re Anderson Homes, Inc. Before the 90-day preference period, on average, the debtor paid the creditor 48.83 days after a purchase order; during the preference period, the average was 95.23 days (or 96.26 days if disputed entries are excluded). This increase of 95.02 percent (or 97.13 percent if disputed entries are excluded) represents a substantial change in the parties’ dealings during the preference period from the pre-preference period.

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