See, In re Wilkinson, 196 Fed.Appx. at 343 (recognizing a reduction in debt is sufficient to establish equivalent value); In re Southeast Waffles, LLC, 702 F.3d at 857. See also, For Your Ease Only, Inc. v. Calgon Carbon Corp., 560 F.3d 717, 722 (7th Cir. 2009)(brother-in-law's three years of labor to create business with retailer was reasonably equivalent value of business that labor created); Parris v. Union Plants Bank of Ky. N.S., (In re Vaughn), 244 B.R. 631, 634 (Bankr. W.D. Ky. 2000)("[T]he record is devoid of any facts that would support a finding that the farming services Debtor received from [Defendant] was 'less than [the] reasonably equivalent value' of the transfer at issue."). Cf. Reed v. Genter (In re Genter), 2021 WL 1112538, at *6, 2021 Bankr. LEXIS 720, at **17-18 (Bankr. N.D. Tex. Mar. 23, 2021)(court found, in part, that debtor received less than a reasonably equivalent value for transferring title to a 1963 Chevrolet Impala SS in exchange for satisfying defendant's right to payment for cleaning and repair services, which defendant valued at $2,400.
See, In re Wilkinson, 196 F. App'x at 343 (recognizing a reduction in debt is sufficient to establish equivalent value); In re Southeast Waffles, LLC, 702 F.3d at 857. See also, For Your Ease Only, Inc. v. Calgon Carbon Corp., 560 F.3d 717, 722 (7th Cir. 2009)(brother-in-law's three years of labor to create business with retailer was reasonably equivalent value of business that labor created); Parris v. Union Plants Bank of Ky. N.S., (In re Vaughn), 244 B.R. 631, 634 (Bankr. W.D. Ky. 2000)("[T]he record is devoid of any facts that would support a finding that the farming services Debtor received from [Defendant] was 'less than [the] reasonably equivalent value' of the transfer at issue."). Cf. Reed v. Genter (In re Genter), 2021 WL 1112538, at *6, 2021 Bankr. LEXIS 720, at **17-18 (Bankr. N.D. Tex. Mar. 23, 2021)(court found, in part, that debtor received less than a reasonably equivalent value for transferring title to a 1963 Chevrolet Impala SS in exchange for satisfying defendant's right to payment for cleaning and repair services, which defendant valued at $2,400.
The new ยง 550(c) was intended to override the Deprizio line of cases and clarify that noninsider transferees should not be required to return payments made beyond the 90-day statutory period. Parris v. Union Planters Bank ofKy. et al. (In re Vaughn), 244 B.R. 631, 633 (Bankr. W.D. Ky. 2000) (citing H.R. Rep. 103-835, 103rd Cong., 2nd Sess. 19-20 (Oct. 4, 1994); 140 Cong. Rec. H10767 (Oct. 4, 1994)). See also S. REP. No. 103-168, at 48 (1993) and H.R. REP. NO. 103-835, at 44-45 (1994).