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The ability of a bankruptcy trustee to avoid certain transfers of a debtor s property and to recover the property or its value from the transferees is an essential tool in maximizing the value of a bankruptcy estate for the benefit of all stakeholders. However, a ruling recently handed down by the U.S. Court of Appeals for the Tenth Circuit could, if followed by other courts, curtail a trustee s avoidance and recovery powers. In
Rajala v. Spencer Fane LLP (In re Generation Resources Holding Co.), 964 F.3d 958 (10
th Cir. 2020),