Idaho Code
Idaho Code

Idaho Code § 55-914 (2026)

Transfer or obligation voidable as to present creditor. 

✓ current as of May 2026
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Transfer or obligation voidable as to present creditor. 

(1) A transfer made or obligation incurred by a debtor is voidable as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor became insolvent as a result of the transfer or obligation.

(2)  A transfer made by a debtor is voidable as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to believe that the debtor was insolvent.
(3)  Subject to section 55-911(2), Idaho Code, a creditor making a claim under subsection (1) or (2) of this section has the burden of proving the elements of the claim by a preponderance of the evidence.
Notes of Decisions
Cited in 17 cases (4 in the last 5 years), 1993–2026 · leading case: Hillen v. City of Many Trees (In re CVAH, Inc.), 570 B.R. 816 (Bankr. D. Idaho 2017).
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Hillen v. City of Many Trees (In re CVAH, Inc.), 570 B.R. 816 (Bankr. D. Idaho 2017). · cites it 6× “More particularly, though, as in McDowell, to the extent Trustee is relying upon either Idaho Code § 55-914 or 28 U.S.C. § 3304 (a), both statutes require that IRS be a creditor at the time of the targeted transfers in order to avoid them.”
High Valley Concrete, LLC v. Sargent, 234 P.3d 747 (Idaho 2010). · cites it 8× “Idaho Code § 55-914 (2) states: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to…”
Wilder v. Miller, 17 P.3d 883 (Idaho Ct. App. 2000). · cites it 20× “Relevant Idaho Code Sections Idaho Code § 55-914 (2) provides: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the…”
Post v. Idaho Farmway, Inc., 20 P.3d 11 (Idaho 2001). · cites it 6× “violated I.C. § 55-914(1), which prohibits transfers to defraud creditors.”
Fitzgerald v. Magic Valley Evangelical Free Church, Inc. (In Re Hodge), 200 B.R. 884 (Bankr. D. Idaho 1996). · cites it 6× “With respect to present creditors, Idaho Code § 55-914 provides in relevant part that: A transfer made .”
Zazzali v. Hirschler Fleischer, P.C., 482 B.R. 495 (D. Del. 2012). · cites it 2× “Count 13: Avoidance and Recovery of the Four Year Transfers as Constructively Fraudulent Transfers Count Thirteen seeks avoidance of four years of transfers made to Defendant pursuant to Idaho Code § 55-914 (1). (See D.I. 1 ¶¶ 214-220) Section 55-914(1) of the Idaho Code…”
Zazzali Ex Rel. DBSI, Inc. v. Mott (In Re DBSI, Inc.), 445 B.R. 344 (Bankr. D. Del. 2011). “That count, to the extent it seeks to recover amounts transferred under Idaho Code § 55-914 (2), is time-barred and will be dismissed.”
Alcan Bldg. Prods. v. Peoples, 859 P.2d 374 (Idaho Ct. App. 1993). · cites it 6× “The district court entered judgment in favor of Alcan, applying I.C. § 55-914(2). This statute provides: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the…”
Elsaesser v. Raeon (In Re Goldberg), 235 B.R. 476 (Bankr. D. Idaho 1999). · cites it 4× “A typical use of § 544(b) is avoidance of transfers under state enactments of the Uniform Fraudulent Transfer Act such as Idaho Code § 55-914 . See, e.g., Spurgeon v.”
Zazzali v. Mott (In Re DBSI, Inc.), 447 B.R. 243 (Bankr. D. Del. 2011). “That count, to the extent it seeks to recover amounts transferred under Idaho Code § 55-914 (2), is time-barred and will be dismissed.”
Zazzali v. 1031 Exch. Grp. LLC (In re DBSI Inc.), 476 B.R. 413 (Bankr. D. Del. 2012). “Idaho Code Ann. § 55-914 (1). See also Post v.”
Dunham v. Dunham, 910 P.2d 169 (Idaho Ct. App. 1994). · cites it 4× “§ 55-913(1)(b)2; (2) a debtor's transfer of an asset to an insider for an antecedent debt when the debtor was insolvent is presumed fraudulent, I.C. § 55-914(2); and (3) a person becomes the owner of an equitable interest in the property when part or all of the property's…”
Show all 17 citing cases →
Idaho Code § 55-914(1): 3 cases
Post v. Idaho Farmway, Inc., 20 P.3d 11 (Idaho 2001). “violated I.C. § 55-914(1), which prohibits transfers to defraud creditors.”
Geile v. Wickersham (Bankr. D. Idaho 2023).
Timothy R. Kurtz v. Kalamata Capital Grp., LLC (Bankr. D. Idaho 2026).
Idaho Code § 55-914(2): 4 cases
High Valley Concrete, LLC v. Sargent, 234 P.3d 747 (Idaho 2010). “Idaho Code § 55-914 (2) states: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to…”
Wilder v. Miller, 17 P.3d 883 (Idaho Ct. App. 2000). “Relevant Idaho Code Sections Idaho Code § 55-914 (2) provides: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the…”
Alcan Bldg. Prods. v. Peoples, 859 P.2d 374 (Idaho Ct. App. 1993). “The district court entered judgment in favor of Alcan, applying I.C. § 55-914(2). This statute provides: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the…”
Dunham v. Dunham, 910 P.2d 169 (Idaho Ct. App. 1994). “§ 55-913(1)(b)2; (2) a debtor's transfer of an asset to an insider for an antecedent debt when the debtor was insolvent is presumed fraudulent, I.C. § 55-914(2); and (3) a person becomes the owner of an equitable interest in the property when part or all of the property's…”
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