Idaho Code
Idaho Code § 55-906 (2026)
Transfers in fraud of creditors.
✓ current as of May 2026
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Transfers in fraud of creditors.
Every transfer of property, or charge thereon made, every obligation incurred, and every judicial proceeding taken, with intent to delay or defraud any creditor or other person of his demands, is void against all creditors of the debtor and their successors in interest, and against any person upon whom the estate of the debtor devolves in trust for the benefit of others than the debtor.
Notes of Decisions
Cited in 20
cases, 1958–2018 · leading case: Zazzali Ex Rel. DBSI, Inc. v. Mott (In Re DBSI, Inc.), 445 B.R. 344 (Bankr. D. Del. 2011).
Zazzali Ex Rel. DBSI, Inc. v. Mott (In Re DBSI, Inc.), 445 B.R. 344 (Bankr. D. Del. 2011). “§§ 544 , 547 and 548, under Idaho state fraudulent conveyance statutes, Idaho Code §§ 55-906 , 55-913, 55-914, 55-916, and 55-917, and under the equitable remedies of unjust enrichment and a declaratory judgment that the Agreements are void for lack of consideration.”
TKO Props., LLC v. Young (In Re Young), 214 B.R. 905 (Bankr. D. Idaho 1997). “TKO also seeks to void a transfer of property from Graeber or his probate estate to Young as a fraudulent transfer pursuant to Idaho Code §§ 55-906 , 55-913, and 55-914.”
Zazzali ex rel. DBSI Est. Litig. Trust v. AFA Fin. Grp., LLC (In re DBSI, Inc.), 477 B.R. 504 (Bankr. D. Del. 2012). “§ 5kk, and Idaho Code Ann. §§ 55-906 , 55-913(l)(a), 55-916, and 55-911 Section 544(b) of the Bankruptcy Code permits the trustee to step into the shoes of an existing unsecured creditor who could have avoided an action under *513 state law.”
Sur. Life Ins. v. Rose Chapel Mortuary, Inc., 514 P.2d 594 (Idaho 1973). “— Every transfer of property, or charge thereon made, every obligation incurred, and every judicial proceeding taken, with intent to delay or defraud any creditor or other person of his demands, is void against all creditors of the debtor and their successors in interest, and…”
Mohar v. McLelland Lumber Co., 501 P.2d 722 (Idaho 1972). “” I.C. § 55-906 provides: “Every transfer of property, or charge thereon made, *41 every obligation incurred, and every judicial proceeding taken, with intent to delay or defraud any creditor or other person of his demands, is void against all creditors of the debtor and their…”
Zazzali v. Mott (In Re DBSI, Inc.), 447 B.R. 243 (Bankr. D. Del. 2011). “§§ 544 , 547 and 548, under Idaho state fraudulent conveyance statutes, Idaho Code §§ 55-906 , 55-913, 55-914, 55-916, and 55-917, and under the equitable remedies of unjust enrichment and a declaratory judgment that the Agreements are void for lack of consideration.”
Zazzali v. 1031 Exch. Grp. LLC (In re DBSI Inc.), 476 B.R. 413 (Bankr. D. Del. 2012). “Count Six—Transfers in Fraud of Creditors under Idaho Code Ann. §§ 55-906 , and 11 U.S.C.”
Zazzali v. Hirschler Fleischer, P.C., 482 B.R. 495 (D. Del. 2012). “Count 14: Transfers in Fraud of Creditors Count Fourteen seeks to recover all payments made to Defendant during the *522 four years prior to the petition date pursuant to Idaho Code § 55-906 , which has the same operative language as the provisions that are the basis of Counts…”
Zazzali Ex Rel. DBSI Est. Litig. Trust v. Swenson (In Re DBSI, Inc.), 463 B.R. 709 (Bankr. D. Del. 2012). “The Motion does not address § 548, but challenges Trustee’s right to seek recovery under § 544(b)(1), incorporating Idaho’s fraudulent transfer statutes, Idaho Code Ann. §§ 55-906 , 55-913, 55-914, 55-916, and 55-917 (the “State Laws”).”
United States v. John P. Bertie, as Tr., 529 F.2d 506 (9th Cir. 1976). “” If the district court properly found that the appellants made the transfers with actual intent to defraud creditors, the judgment setting aside the conveyance was not only proper, but mandated by Idaho law.”
Haney v. Molko, 844 P.2d 1382 (Idaho Ct. App. 1992). “Idaho’s Unlawful Transfers statute, I.C. § 55-906, provides that: Every transfer of property .”
Elsaesser v. Raeon (In Re Goldberg), 235 B.R. 476 (Bankr. D. Idaho 1999). “Idaho 1996) (use of Idaho Code § 55-906 , 913 and 914). In this case, the Trustee has not alleged the existence of an actual unsecured creditor with a right of transfer avoidance under state law as to the two subject liens, nor has he established the relevant and controlling…”
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