. For example, in In re Evans Potato Co., Inc. (Butz v. Sohigro Service Co.), 44 B.R. 191, 193-194 (Bankr.S.D.Ohio 1984) the court held that the debtor corporation received reasonably equivalent value for payment of an individual's debt because the debtor received the goods for which the debt was incurred. Here, Prescott alleges that the benefit received by CM W was the acquisition of the Rail Assets and the financing.

This Court has previously cited with approval a case originating in the Southern District of Ohio, which is directly analogous to the proceeding at bar. See Hall v. Arthur Young and Co. ( In re Computer Universe, Inc.), 58 B.R. 28, 31 (Bankr.M.D.Fla.1986) (citing In re Evans Potato Co., Inc. (Butz v. Sohigro Service Co.), 44 B.R. 191 (Bankr.S.D.Ohio 1984)). In Evans Potato Co., the court held that a debtor corporation had received fair consideration (or reasonably equivalent value) for payment of its principal's debt because it had exclusive use of the goods purchased.

The court also denied recovery of the payments as fraudulent transfers because the corporation actually received the benefit, the potatoes, that gave rise to the debt and the payments. In re Evans Potato Company, Inc., 44 B.R. 191, 12 Bankr.Ct.Dec. 518 (Bankr.N.D.Ohio 1984). Other courts in similar situations have held that the corporate debtor's transfers are recoverable as fraudulent transfers if they are not recoverable as preferences, and vice versa.

The exception to the proposition advanced by Coors of North Mississippi is that if the payer received some benefit by the payment of a debt owed by a third party, then the payment can still be for reasonably equivalent value. See Matter of Evans Potato Co., Inc., 44 B.R. 191, 193-94 (Bankr.S.D.Oh. 1984), and In Re Jamison, 21 B.R. 380, 381-82 (Bankr.D.Ct. 1982). Since Moak applied each of these payments to the Coors of North Mississippi indebtedness at Planters Bank, the benefit to Coors of North Mississippi is obvious — for each dollar paid, it received a dollar reduction in the amount that it owed.

"The general rule is that payment of or assumption of a third party's debt by an insolvent is a transfer without fair consideration and is thus fraudulent." Butz v. Sohigro Serv. Co. (In re Evans Potato Co. Inc.), 44 B.R. 191, 193 (S.D. Ohio 1984); see Rubin v. Mfrs. Hanover Trust Co., 661 F.2d 979, 991 (2d Cir. 1981) (concerning the analogous former fraudulent transfer provision under 11 U.S.C. § 107(d)). But an insolvent debtor's payment on behalf of a third party is not avoidable if the transfer "confers an economic benefit upon the debtor, either directly or indirectly."

(Appellee's Brief, 15). By GECC's own description of Domino's operations, it is evident that Domino could not have made use of an airplane, and that the use of an airplane would not have conferred an economic benefit upon the corporation. In support of its argument that Domino received "reasonably equivalent value" through the use of the plane, GECC cites In re Evans Potato Co., 44 B.R. 191 (Bankr.S.D.Ohio, 1984). In Evans Potato, an individual bought goods on his own account which were then shipped to, and used by, a debtor corporation.

The Trustee has failed to prove the first two elements of an avoidable preference under section 547(b)(1) (2). In re Chase Sanborn Corp., 68 B.R. 530, 532 (Bankr. S.D.Fla. 1986), aff'd, 848 F.2d 1196 (11th Cir. 1988); see Matter of Evans Potato Co., Inc., 44 B.R. 191, 193 (Bankr.S.D.Ohio 1984) (citing multiple cases for the proposition that "there can be no preference when there is no debtor-creditor relationship" under section 547(b)). Importantly, the Trustee fails to address how it "may avoid an interest of the debtor [Connaught] in [the Westport] property" under section 547(b).

Other courts have concluded that the fact that value flowed to the debtor through a third party does not necessarily bar a finding that the debtor received reasonably equivalent value. See Rubin, 661 F.2d at 993; In re Holly Hill Medical Center, Inc., 44 B.R. 253, 255 (Bkrtcy.M.D.Fla. 1984); In re Evans Potato Co., 44 B.R. 191, 194 (Bkrtcy.S.D.Ohio 1984). In each of these cases, a third party arranged or secured a loan for the benefit of the debtor.

This purpose would not be served if the debtor received an economic benefit as "the debtor's net worth has been preserved, and the interests of the creditors will not have been injured by the transfer."In re PSN USA, Inc. , 615 F. App'x 925, 928 (11th Cir. 2015) (quoting In re Evans Potato Co. Inc. , 44 B.R. 191, 193 (Bankr. S.D. Ohio 1984) ). 895 F.2d 725, 727 (11th Cir. 1990).

It is the third exception that is applicable here, where the Debtor received the primary, tangible benefit of the right to occupy the premises. In Matter of Evans Potato Co., Inc., 44 B.R. 191 (Bankr. S.D. Ohio 1984), relied upon by MCB, a critical vendor cut off the debtor's ability to purchase its goods on credit due to unfavorable credit reports. The debtor's landlord was able to purchase the needed goods on credit in his own name and provide them to the debtor for its use.