Two-Year Look-Back Period in 11 U.S.C. § 548 is Not a Statute of Limitations Subject to Equitable Tolling
Industrial Enterprises of America, Inc. v. Burtis (In re Pitt Penn Holding Co., Inc.), Case No. 09-11475 (BLS) (Jointly Administered), Adv. No. 11-51868 (BLS) (January 24, 2012) (J. Shannon) The Court was faced with numerous adversary proceedings