of the First Amendment. However, the court’s analysis in In re Green, has been seriously undermined by Employment Div., Dept. of Human Resources of Oregon v. Smith, 494 U.S. 872, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990) in which the Supreme Court held: [I]f prohibiting the free exercise of religion ... is not the object of the [law] but merely the incidental effect of a generally applicable and otherwise valid provision, the First Amendment has not been offended. In re Lynn, 168 B.R. 693, 697 (Bankr.D.Ariz.1994) (quoting, Employment Div. v. Smith, 494 U.S. at 878, 110 S.Ct. at 1599-1600). Three bankruptcy courts have held that Smith stands for the proposition that the Bankruptcy Code need not yield to a debtor’s desire to tithe. See In re Young, 152 B.R. 939, 951 (Bankr.D.Minn.1993) (<HOLDING>); In re Lee, 162 B.R. 31, 42
holding that a plaintiff must plead with specificity as to the statements or omissions considered to be fraudulent the speaker when and why the statements were made and an explanation of why they were fraudulent holding that because an action under the texas fraudulent transfers act is essentially one for property that properly belongs to the debtor the cause of action belongs to the debtor holding that the transfers at issue were not fraudulent transfers because  they did not diminish the debtors estate holding that donations to churches could be considered preferences and or fraudulent transfers holding that the plaintiffs mere failure to execute on a judgment the only allegedly fraudulent act is not fraudulent concealment