In re Houston, 385 B.R. 268 (Bankr. N.D. Iowa 2008)

(debtor’s transfer of one-half interest in farmland to mother within five months of filing bankruptcy does not constitute actual fraud under11 U.S.C. §548(a)(1)(A), but is constructive fraud under 11 U.S.C. §548(a)(1) (B); debtor had interest in the land, voluntarily transferred it to his mother within a year of filing bankruptcy, received less that equivalent value for the deed and became insolvent as a result of the transfer; bankruptcy trustee entitled to sell the farmland to pay mother for her interest and also entitled to debtor’s share of CRP payments related to the farmland).