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    SmartBrief enables case brief popups that define Key Terms, Doctrines, Acts, Statutes, Amendments and Treatises used in this case.

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    Bankruptcy Keyed to Bussel, 12th Ed.

    Matter of Clark Pipe & Supply Co.

    Citation:

    893 F.2d 693 (1990)

    Facts

    Clark Pipe and Supply Company was in the business of buying and selling steel pipe for offshore drilling platforms. In September 1980, Clark entered into loan agreements with Associates Commercial Corporation, under which Associates would make revolving loans secured by accounts receivable and inventory. The loan amount was determined by a formula: a percentage of eligible accounts receivable plus a percentage of inventory cost. The agreements allowed Associates to reduce the percentage advance rates at its discretion.

    When the oil industry declined in late 1981, Clark’s business slumped. In February 1982, Associates began reducing the percentage advance rates so that Clark had just enough cash to pay direct operating expenses. Clark used these advances to keep operating and sell inventory, with the proceeds used to pay off past advances from Associates. While Associates did not explicitly dictate which bills Clark should pay, the reduced funding meant Clark had no funds to pay vendors or other non-essential creditors.

    Several unpaid vendors initiated foreclosure proceedings against Clark between February and May 1982. When a third creditor began foreclosure in May, Clark filed for Chapter 11 bankruptcy protection. The case was later converted to Chapter 7 liquidation. The bankruptcy trustee then brought an action against Associates, seeking to recover alleged preferences and equitable subordination of Associates’ claims.

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    Matter of Clark Pipe & Supply Co.