In re McGough, 467 B.R. 220 (B.A.P. 10th Cir. 2012)

(under 11 U.S.C. Sec. 548(a)(2)(A), bankruptcy trustee could avoid portion of charitable contributions debtors made to church over two-year period before bankruptcy filing that exceeded 15 percent of debtors' gross annual income; trustee's argument that statute requires debtors' contributions (which exceeded 15 percent threshold in both preceding years) be avoided in their entirety is rejected).