test applies post-confirmation in reorganization cases because "it is assumed the reorganized debtor is becoming self-sufficient, and no longer needs umbrella protection from the bankruptcy court. Additionally, there is no estate, as property reverts to the reorganized debtor.” In re Park Ave. Radiologists, P.C., 450 B.R. 461, 468 (Bankr.S.D.N.Y.2011). Some courts apply the "close nexus” test even when the debtor liquidates; other courts apply the “conceivable effect” test. See Allstate Ins. Co. v. CitiMortgage, Inc., No. 11 Civ.1927(RJS), 2012 WL 967582, at *5 (S.D.N.Y. Mar. 13, 2012) (summarizing the division within the circuit). This Court previously applied the conceivable effect test in a liquidation case. See In re Cross Media Mktg. Corp., 367 B.R. 435, 444 (Bankr.S.D.N.Y.2007) (<HOLDING>). The Court adopted the reasoning of the First
holding that a liquidating trust established by a chapter 11 debtor to bring actions to avoid fraudulent and preferential transfers was not bound by an agreement between defendants and the debtor to arbitrate disputes as the trustee of the liquidating trust was bringing the avoidance actions on behalf of creditors holding that a bankruptcy courts jurisdiction does not diminish post confirmation if the debtor pursuant to a liquidating plan seeks to commence litigation to collect the debtors assets for the benefit of its creditors holding that following confirmation of the debtors chapter 11 plan the internal revenue service could collect a nondischargeable tax claim that was not listed in the irss bankruptcy claim holding that the debtor in possession could utilize the strongarm powers of the trustee to avoid an unperfected security interest even though the debtor knew of the interest prior to bankruptcy because the two are distinct entities and the debtor in possessions responsibility is to preserve the estates assets for the benefit of the creditors holding that the purpose of the bankruptcy codes avoidance provisions is to prevent a debtor from making transfers that diminish the bankruptcy estate to the detriment of creditors