Tennessee Code Annotated

Tenn. Code Ann. § 66-3-306 (2026)

Transfers fraudulent as to present creditors

✓ current as of May 2026
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Acts 2003, ch. 42, § 1.


Notes of Decisions
Cited in 22 cases (5 in the last 5 years), 1984–2026 · leading case: Nippert v. Jackson, 860 F. Supp. 2d 554 (M.D. Tenn. 2012).
Nippert v. Jackson, 860 F. Supp. 2d 554 (M.D. Tenn. 2012). · cites it 8× “Tenn. Code Ann. § 66-3-306 (2004). Thus, this section addresses constructive fraud.”
Guinn v. Lines (In Re Trans-Lines West, Inc.), 203 B.R. 653 (Bankr. E.D. Tenn. 1996). · cites it 6× “Tenn.Code Ann. § 66-3-306 (1993). Conveyances before debt incurred.”
Webb Mtn, LLC v. Exec. Realty P'ship, L.P. (In Re Webb Mtn, LLC), 420 B.R. 418 (Bankr. E.D. Tenn. 2009). · cites it 4× “§ 544 (b) (2006); (2) if so, whether the release from escrow and/or the recording of the Franklin Quit Claim Deed regarding the 1,445 acre Franklin Tract on September 18, 2007, is avoidable by the Plaintiff pursuant to Tennessee Code Annotated § 66-3-305 (2004) and/or Tennessee…”
Paris v. Walker (In re Walker), 566 B.R. 503 (Bankr. E.D. Tenn. 2017). · cites it 4× “Tenn. Code Ann. § 66-3-306 (a). If a trustee seeks any remedy available under TFTA section 308, he or she must bring the cause of action within four years after the transfer was made or the obligation was incurred.”
Fed. Deposit Ins. Corp. v. Allen, 584 F. Supp. 386 (E.D. Tenn. 1984). · cites it 2× “, and the main purpose in setting up Valley Rental was to use that company to borrow money.”
Webb Mtn, LLC v. Exec. Realty P'ship (In Re Webb Mtn, LLC), 414 B.R. 308 (Bankr. E.D. Tenn. 2009). · cites it 4× “Tenn.Code Ann. § 66-3-306. Reading the two constructive fraud statutes together, they require proof that: The debtor did not receive reasonably equivalent value in exchange for the transfer; and (1) the debtor was engaged in or about to engage in business or transaction for…”
Farinash v. Silvey (In Re Silvey), 378 B.R. 186 (Bankr. E.D. Tenn. 2007). · cites it 5× “Tenn.Code Ann. §§ 66-3-306 & 66-3-101; see In re Turner, 78 B.”
Crocker v. Ryan, 914 S.W.2d 551 (Tenn. Ct. App. 1995). · cites it 4× “Ryan was not rendered insolvent by the transfer, it was not fraudulent under the provisions of Tenn.Code Ann. § 66-3-305. 1 There are, however, other sections of the Code that render certain conveyances fraudulent as to present or future creditors.”
In Re Turner, 78 B.R. 166 (Bankr. E.D. Tenn. 1987). · cites it 2× “Tenn.Code Ann. § 66-3-306. The third constructive fraud statute requires proof *169 that the transfer was made or the debt incurred by a debtor when she intended or believed that she would incur debts beyond her ability to pay as they matured.”
Brown v. Riley (In Re Omni Mech. Contractors, Inc.), 114 B.R. 518 (Bankr. E.D. Tenn. 1990). · cites it 2× “§ 66-3-306. Insolvency is defined in § 66-3-302 of the Act as follows: A person is insolvent when the present fair salable value of his assets is less than the amount that will be required to pay his probable liability on his existing debts as they become absolute and matured.”
Delta Gypsum, LLC v. Michael Felgemacher (Tenn. Ct. App. 2017). · cites it 16× “The trial court found the supplier was unable to satisfy the elements of either the actual fraud statute, Tenn. Code Ann. § 66-3-305 (a)(1), or the constructive fraud statute, Tenn.”
Auto. Experts, Inc. v. Kallberg (M.D. Tenn. 2021). · cites it 14× “Fraudulent Conveyance under Tenn. Code Ann. § 66-3-306 (a), and IV) Fraudulent Conveyance under Tenn.”
— Tenn. Code Ann. § 66-3-306(a) — 5 cases
Webb Mtn, LLC v. Exec. Realty P'ship, L.P. (In Re Webb Mtn, LLC), 420 B.R. 418 (Bankr. E.D. Tenn. 2009). “§ 544 (b) (2006); (2) if so, whether the release from escrow and/or the recording of the Franklin Quit Claim Deed regarding the 1,445 acre Franklin Tract on September 18, 2007, is avoidable by the Plaintiff pursuant to Tennessee Code Annotated § 66-3-305 (2004) and/or Tennessee…”
Mostoller v. Garrett (Bankr. E.D. Tenn. 2022).
Lindsey v. Collier (M.D. Tenn. 2021).
Karen Stoner v. Brittany C. Amburn (Tenn. Ct. App. 2012).
— Tenn. Code Ann. § 66-3-306(b) — 1 case
Lindsey v. Collier (M.D. Tenn. 2021).
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