The ‘billing approach,’ not the ‘accrual approach,’ decides whether there is a priority claim for personal property and real estate leases more than 60 days after filing.

There is no prohibited double recovery from multiple defendants, the appeals courts says, until the trustee has recovered cash equaling the value of the fraudulently transferred property.

Second Circuit won’t give a defendant a windfall if the debtor scheduled the lawsuit in the wrong place but told the trustee and the court.

Dismissing the debtor as plaintiff is not a final order when the trustee is substituted.