Cases from cite.case.law:

ELLIOT CALLAN, INC. a v. CROFTON,, 615 F. Supp. 2d 963 (D. Minn. 2009)

. . . But, at the time, the net amount of the fraudulent transfers from SCC to Crofton was $255.02. . . . The excess “new value” — that is, the difference between $280 and $255.02 — was written off. 22. . . .

FILIPOWICZ v. ROTHENSIES,, 43 F. Supp. 619 (E.D. Pa. 1942)

. . . or about November 1, 1938, the Commissioner duly made an assessment against the United Coat Shop of $255.02 . . .