Am. Banltr.L.J. 247, 257-64 (1997). 31 . Section 523(a)(2)(A) provides: (a) A discharge under section 727, 1141, 1228(a), 1228(b), or 1328(b) of this title does not discharge an individual from any debt (2) for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by— (A) false pretenses, a false representation, or actual fraud, other than a statement respecting the debtor's or an insider’s financial condition; 11 U.S.C. § 523(a)(2)(A). 32 . AT&T Universal Card Serv. Corp v. Feld (In re Feld), 203 B.R. 360, 364 (Bankr.E.D.Pa.1996). 33 . 11 U.S.C. § 523(a)(2)(A). 34 . See, e.g., AT&T Universal Card Serv. v. Alvi (In re Alvi), 191 B.R. 724, 729 (Bankr.N.D.Ill.1996). 35 . Id. See also FCC Nat'l Ba Burns), 196 B.R. 11, 14 (Bankr.W.D.N.Y.1996) (<HOLDING>). 81 . 11 U.S.C. § 523(a)(2)(C). 82 . S.Rep.
holding debtor could include property because the bank accepted payments directly from the debtor and had previously allowed the debtor to cure default holding creditor does not have to prove it investigated debtors creditworthiness if debtor does not claim the card was preapproved and debtor was insolvent at the time recognizing that if a debtor did not satisfy section 109e and if it was jurisdictional the court could not convert debtors case because it would have no authority whatever over debtor holding that the principal of a corporate debtor does not become a transferee by the mere act of causing the debtor to make a fraudulent transfer holding that debtors actions were not willful where there was a creditor which the debtor chose to pay first and thought that it was in his financial interest to do so